Tariff Order DNHPDCL 2021-22

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TARIFF ORDER

True-up of FY 2019-20, Annual Performance Review of FY 2020-21,


Aggregate Revenue Requirements (ARR) and Determination of Retail
Tariff for FY 2021-22

Petition No. 37/2020

For

DNH Power Distribution Corporation Limited

23rd March, 2021


JOINT ELECTRICITY REGULATORY COMMISSION
For the State of Goa and Union Territories,
3rd and 4th Floor, Plot No. 55-56,
Sector -18, Udyog Vihar - Phase IV
Gurugram, (122015) Haryana
Telephone: +91(124) 4684705 Telefax: +91(124) 4684706
Website: www.jercuts.gov.in
E-mail: [email protected]
Table of Contents

1. Chapter 1: Introduction 15

About Joint Electricity Regulatory Commission (JERC) 15


About Dadra and Nagar Haveli 15
DNH Power Distribution Corporation Ltd. 16
Multi Year Distribution Tariff Regulations, 2014 16
Multi Year Tariff Regulations, 2018 17
Approval of Business Plan for 2nd MYT Control Period 17
Multi Year Tariff Order for 2nd MYT Control Period 17
Approval of True Up for FY 2018-19, APR for FY 2019-20 and ARR & Tariff for FY 2020-21 17
Filing and Admission of the Present Petition 17
Interaction with the Petitioner 17
Notice for Public Hearing 18
Public Hearing 18

2. Chapter 2: Summary of Suggestions/Comments received, Response from the Petitioner and


the Commission’s Views 20

Regulatory Process 20
Suggestions/ Comments, Response of the Petitioner and Commission’s Views 20
2.2.1. True up of FY 2019-10 20

2.2.1.1. Return on Equity 20


2.2.1.2. Interest on finance charges 21
2.2.1.3. Non-Tariff Income 21
2.2.1.4. Income Tax 21
2.2.1.5. Interest on Working Capital 22
2.2.1.6. Revenue from sale of power 23
2.2.1.7. Revenue Gap/ Surplus 23
2.2.2. Annual Performance Review of FY 2020-21 24

2.2.2.1. Distribution Losses 24


2.2.2.2. Power Requirement 24
2.2.2.3. Power Purchase Cost 24
2.2.2.4. Return on equity 25
2.2.2.5. Non-Tariff Income 25
2.2.2.6. Income Tax 25
2.2.2.7. Interest on Working Capital 26
2.2.3. ARR for FY 2021-22 27

2.2.3.1. Distribution Losses 27


2.2.3.2. Power Purchase Cost 27
2.2.3.3. Return on equity 28

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 2
DNH Power Distribution Corporation Limited (DNHPDCL)
2.2.3.4. Non-Tariff Income 28
2.2.3.5. Income Tax 28
2.2.3.6. Interest on working capital 29
2.2.3.7. Computation of Renewable Purchase obligation 30
2.2.3.8. Computation of Cross Subsidy Surcharge 30
2.2.3.9. Computation of Additional Surcharge 31
2.2.3.10. Power Exchange as a part of Merit Order Despatch 31
2.2.3.11. Renewable Power from GTAM market 32
2.2.4. Other Issues 32

2.2.4.1. Non Utilization of Interest on Normative loan 32


2.2.4.2. Sharing of the benefits of savings made by reduction in line loss 32
2.2.4.3. Asset by contribution of consumers 33
2.2.4.4. Performance Standards reports to be uploaded on website. 33
2.2.4.5. Cross Subsidization between EHT/ HT & LT Consumers 33

3. Chapter 3: True-up for FY 2019-20 35

Background 35
Approach for the True-Up of FY 2019-20 35
Energy Sales 35
Open Access Sales 37
Inter-State Transmission Loss 37
Distribution Loss 37
Energy Balance 38
Power Purchase Quantum & Cost 39
Renewable Purchase Obligation (RPO) 44
Operation & Maintenance Expenses 46
3.10.1. Employee Expenses 46
3.10.2. Administrative and General (A&G) Expenses 47
3.10.3. Repair & Maintenance Expenses (R&M) 48
3.10.4. Total Operation and Maintenance Expenses (O&M) 48

Gross Fixed Assets (GFA) and Capitalization 49


Capital Structure 49
Depreciation 51
Interest on Loan 52
Return on Equity (RoE) 54
Additional ROE for FY 2016-17, FY 2017-18 and FY 2018-19 55
Interest on Security Deposits 56
Interest on Working Capital 57
Income Tax 58
Provision for Bad & Doubtful Debts 60
Non-Tariff Income (NTI) 61
Incentive/Disincentive towards over/under achievement of norms of distribution losses 62

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 3
DNH Power Distribution Corporation Limited (DNHPDCL)
Aggregate Revenue Requirement (ARR) 63
Revenue at existing Retail Tariff 64
Standalone Revenue Gap/ Surplus 64

4. Chapter 4: Annual Performance Review for FY 2020-21 65

Background 65
Approach for the Review for FY 2020-21 66
Energy Sales 67
Inter-State Transmission Loss 68
Distribution Loss 68
Energy Balance 69
Power Purchase Quantum & Cost 71
4.7.1. Availability of power 71
4.7.2. Power Purchase Cost 73
4.7.3. Transmission Charges 75
4.7.4. Total power purchase quantum and cost approved by Commission 76

Renewable Purchase Obligation (RPO) 77


Operation & Maintenance Expenses 80
4.9.1. Employee Expenses 82
4.9.2. Administrative and General (A&G) Expenses 83
4.9.3. Repair & Maintenance Expenses (R&M) 83
4.9.4. Total Operation and Maintenance Expenses (O&M) 84

Gross Fixed Assets (GFA) and Capitalization 84


Capital Structure 85
Depreciation 86
Interest on Loan 88
Return on Equity (RoE) 90
Interest on Security Deposits 92
Interest on Working Capital 92
Income Tax 94
Provision for Bad & Doubtful Debts 94
Non-Tariff Income 95
Aggregate Revenue Requirement (ARR) 96
Revenue at existing Retail Tariff 97
FPPCA Computation 98
Standalone Revenue Gap/Surplus 99

5. Chapter 5: Determination of Aggregate Revenue Requirement for FY 2021-22 101

Background 101
Approach for determination of ARR for the FY 2021-22 101
Projection of Number of consumers, Connected Load and Energy Sales 101
Inter-State Transmission Loss 103

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 4
DNH Power Distribution Corporation Limited (DNHPDCL)
Distribution Loss 103
Energy Balance 104
Power Purchase Quantum & Cost 106
5.7.1. Availability of power 106
5.7.2. Power Purchase Cost 108
5.7.3. Transmission Charges 111
5.7.4. Total power purchase quantum and cost approved by Commission 112

Renewable Purchase Obligation (RPO) 115


Operation & Maintenance Expenses 117
5.9.1. Employee Expenses 118
5.9.2. Administrative and General (A&G) Expenses 120
5.9.3. Repair & Maintenance Expenses (R&M) 120
5.9.4. Total Operation and Maintenance Expenses (O&M) 121

Gross Fixed Assets (GFA) and Capitalization 122


5.10.1. Analysis of GFA and capitalization for the control period (FY 2019-20 to FY 2021-22) 122

Capital Structure 123


Depreciation 124
Interest on Loan 126
Return on Equity (RoE) 129
Interest on Security Deposits 131
Interest on Working Capital 131
Income Tax 133
Provision for Bad & Doubtful Debts 134
Non-Tariff Income 134
Aggregate Revenue Requirement (ARR) 136
Revenue at existing Retail Tariff 136
Standalone Revenue Gap/ Surplus 138

6. Chapter 6: Tariff Principles and Design 139

Overall Approach 139


Applicable Regulations 139
Cumulative Revenue Gap/ Surplus at Existing Tariff 140
Treatment of the cumulative Gap/Surplus and Tariff Design 141

6.4.2.1. Approval of kVAh based billing for LT Industrial Consumers 146


6.4.2.2. Existing and retail Tariff for FY 2021-22 146
6.4.5. Highlights of the Tariff Structure 149

7. Chapter 7 Open Access Charges for the FY 2021-22 151

Determination of Additional Surcharge 151


Determination of Wheeling Charges 152
7.2.1. Allocation Matrix - Allocation of ARR into Wheeling and Retail Supply of Electricity 152

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 5
DNH Power Distribution Corporation Limited (DNHPDCL)
Cross-Subsidy Surcharge 155
Other Charges 157

8. Chapter 8: Fuel and Power Purchase Adjustment Mechanism 158

Legal Provisions 158


Existing Formula 159

9. Chapter 9: Directives 163

Directives Continued/ Dropped in this Order 163


9.1.1. Quarterly Statement of Capital Expenditure 163
9.1.2. Implementation of Smart Grid 164
9.1.3. Information for determination of Voltage-wise Wheeling Charges 164
9.1.4. Timely Submission of Reports 164
9.1.5. Quarterly RPO Compliance Report Submission 165
9.1.6. Quarterly details of Stranded Power (Open Access) 165
9.1.7. Status of Metering 165

10. Chapter 10: Tariff Schedule 166

Tariff Schedule 166


Applicability 167
General Conditions of HT and LT Supply 168
Schedule of Miscellaneous Charges 170

Annexures 172

Annexure I: List of Stakeholders 172

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 6
DNH Power Distribution Corporation Limited (DNHPDCL)
List of Tables
Table 1: Standalone Revenue Gap/ (Surplus) approved for FY 2019-20 (INR Crore) ......................................... 13
Table 2: Standalone Revenue Gap/ (Surplus) approved for FY 2020-21 (INR Crore) ......................................... 13
Table 3: Standalone Revenue Gap/ (Surplus) approved for FY 2021-22 (INR Crore) ......................................... 13
Table 4: Cumulative Revenue Gap/ (Surplus) approved by Commission (INR Crore) ........................................ 13
Table 5: Transmission & Distribution System of DNHPDCL .................................................................................. 16
Table 6: List of interactions with the Petitioner .......................................................................................................18
Table 7: Details of Public Notices published by the Petitioner ................................................................................18
Table 8: Details of Public Notices published by the Commission ............................................................................18
Table 9: Energy Sales submitted by the Petitioner for FY 2019-20 (MU) ............................................................. 36
Table 10: Energy Sales trued-up by the Commission for FY 2019-20 (MU) ......................................................... 36
Table 11: Inter-State Transmission Loss for FY 2019-20 (%)................................................................................. 37
Table 12: Distribution loss approved by Commission for FY 2019-20 (%) ........................................................... 38
Table 13: Energy requirement submitted by the Petitioner for FY 2019-20 (MU) ............................................... 38
Table 14: Energy balance approved by Commission for FY 2019-20 (in MU) ..................................................... 39
Table 15: Power Purchase cost submitted by the Petitioner for FY 2019-20 ....................................................... 40
Table 16: Power Purchase quantum and cost approved by the Commission for FY 2019-20 ............................. 42
Table 17: Summary of Renewable Purchase Obligation (RPO) for FY 2019-20 (MU) ........................................ 45
Table 18: Employee Expenses approved by Commission for FY 2019-20 (INR Crore) ....................................... 47
Table 19: A&G Expenses approved by Commission for FY 2019-20 (INR Crore) ................................................ 47
Table 20: R&M Expenses approved by Commission for FY 2019-20 (INR Crore) .............................................. 48
Table 21: O&M Expenses approved by Commission for FY 2019-20 (INR Crore) ............................................... 48
Table 22: Capitalization approved by Commission for FY 2019-20 (INR Crore) ................................................ 49
Table 23: Funding Plan approved by the Commission for FY 2019-20 (INR Crore) ........................................... 50
Table 24: GFA addition approved by Commission for FY 2019-20 (INR Crore) ................................................. 50
Table 25: Normative Loan addition for FY 2019-20 (INR Crore) ......................................................................... 50
Table 26: Normative Equity addition for FY 2019-20 (INR Crore) ...................................................................... 50
Table 27: Depreciation Rate (%) ................................................................................................................................ 51
Table 28: Depreciation approved by Commission for FY 2019-20 (INR Crore) .................................................. 52
Table 29: Interest on Loan approved by Commission for FY 2019-20 (INR Crore) ............................................ 53
Table 30: Return on Equity approved by Commission for FY 2019-20 (INR Crore) ........................................... 55
Table 31: Interest on security deposit approved by Commission for FY 2019-20 (INR Crore) ...........................57
Table 32: Interest on Working Capital submitted by Petitioner for FY 2019-20 (INR Crore) .............................57
Table 33: Interest on Working Capital approved by Commission for FY 2019-20 (INR Crore) ........................ 58
Table 34: Income Tax approved by Commission for FY 2019-20 (INR Crore) .................................................... 60
Table 35: Non-Tariff Income Approved by Commission for FY 2019-20 (INR Crore) ........................................ 62
Table 36: Incentive due to over-achievement of Distribution Loss target for FY 2019-20 (INR Crore) ............ 63
Table 37: Aggregate Revenue Requirement approved by Commission for FY 2019-20 (INR Crore) ................ 63
Table 38: Standalone Revenue Gap/ (Surplus) for FY 2019-20 (INR Crore) ....................................................... 64
Table 39: Energy Sales (MU) approved by the Commission for FY 2020-21 ....................................................... 67
Table 40: Inter-State Transmission Loss for FY 2020-21 (%) ............................................................................... 68
Table 41: Distribution loss for FY 2020-21 (%) ....................................................................................................... 68
Table 42: Energy Balance as submitted by the Petitioner for FY 2020-21 (MU) ................................................. 69
Table 43: Energy Balance as approved by the Commission for FY 2020-21 (MU) ............................................. 70
Table 44: Energy allocation as considered by the Petitioner for FY 2020-21 (MW) ............................................ 71
Table 45: Power Purchase Quantum (MU) and Cost (INR Crore) submitted by Petitioner for FY 2020-21 ..... 73
Table 46: Power Purchase Quantum (MU) and cost (INR Crore) approved by the Commission for FY 2020-21
..................................................................................................................................................................................... 76
Table 47: Summary of Renewable Purchase Obligation (RPO) for FY 2020-21 (MU) ........................................ 78
Table 48: Cost towards compliance of Renewable Purchase Obligation for FY 2020-21 (INR Crore) .............. 79
Table 49: Average CPI Inflation Rate (%) ............................................................................................................... 82
Table 50: Employee Expenses approved by Commission for FY 2020-21 (INR Crore) ....................................... 82
Table 51: A&G Expenses approved by Commission for FY 2020-21 (INR Crore) ................................................ 83
Table 52: Computation of WPI Inflation (%) ........................................................................................................... 83
Table 53: R&M approved by the Commission for FY 2020-21 ............................................................................... 84

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 7
DNH Power Distribution Corporation Limited (DNHPDCL)
Table 54: O&M Expenses approved by Commission for FY 2020-21 (INR Crore) ............................................... 84
Table 55: Capitalization approved by the Commission for FY 2020-21 (INR Crore) .......................................... 84
Table 56: Funding Plan approved by the Commission for FY 2020-21 (INR Crore) ........................................... 86
Table 57: GFA addition approved by Commission for FY 2020-21 (INR Crore) .................................................. 86
Table 58: Normative Loan addition for FY 2020-21 (INR Crore) ......................................................................... 86
Table 59: Normative Equity addition for FY 2020-21 (INR Crore) ...................................................................... 86
Table 60: Depreciation approved by Commission for FY 2020-21 (INR Crore) .................................................. 88
Table 61: Interest on Loan approved by Commission for FY 2020-21 (INR Crore) ............................................ 90
Table 62: Return on Equity approved by Commission for FY 2020-21 ................................................................. 91
Table 63: Interest on Security Deposits approved by Commission for FY 2020-21 (INR Crore) ....................... 92
Table 64: Interest on Working Capital submitted by Petitioner for FY 2020-21 ................................................. 92
Table 65: Interest on Working Capital approved by Commission for FY 2020-21 (INR Crore) ........................ 94
Table 66: Income tax approved by Commission for FY 2020-21 (INR Crore) ..................................................... 94
Table 67: Non-Tariff Income approved by Commission for FY 2020-21 (INR Crore) ........................................ 96
Table 68: Aggregate Revenue Requirement approved by the Commission for FY 2020-21 (INR Crore) .......... 96
Table 69: Revenue at existing tariff computed by Commission for FY 2020-21 .................................................. 97
Table 70: FPPCA Rates approved by Commission for FY 2020-21 ....................................................................... 99
Table 71: Computation of Revenue from FPPCA for FY 2020-21........................................................................... 99
Table 72: Revenue from FPPCA allowed by the Commission for FY 2020-21 (INR Crore)................................. 99
Table 73: Standalone Revenue Gap/ (Surplus) at existing tariff for FY 2020-21 (INR Crore) ........................... 99
Table 74: Number of Consumers approved by the Commission for FY 2021-22 ................................................ 102
Table 75: Connected Load approved by the Commission for FY 2021-22 (kW) ................................................. 102
Table 76: Energy Sales projected by the Commission for FY 2021-22 (MUs) .................................................... 102
Table 77: Inter-State transmission loss as approved by the Commission for FY 2021-22 (%) ......................... 103
Table 78: Distribution loss as approved by the Commission for FY 2021-22 (%) .............................................. 104
Table 79: Energy Balance submitted by Petitioner for FY 2021-22 (MU) .......................................................... 104
Table 80: Energy Balance approved by Commission for FY 2021-22 (MU) ...................................................... 104
Table 81: Energy Allocation as submitted by the Petitioner for FY 2021-22 (MW) ........................................... 106
Table 82: Station wise power purchase submitted by Petitioner for FY 2021-22 (MUs) ...................................107
Table 83: Power Purchase quantum (MU) and Cost (INR Crore) submitted by Petitioner for FY 2021-22 .... 109
Table 84: Cost of Solar own generation for FY 2021-22 (INR Crore) ...................................................................111
Table 85: Transmission and other Charges submitted by Petitioner for FY 2021-22 (INR Crore) ................... 112
Table 86: Transmission charges (INR Crore) approved for FY 2021-22 ............................................................. 112
Table 87: Power Purchase Quantum and Cost approved by the Commission for FY 2021-22 .......................... 113
Table 88: Average Power Purchase Cost (APPC) approved for FY 2021-22 ....................................................... 115
Table 89: RPO Plan proposed by the Petitioner for FY 2021-22 (MU)................................................................. 115
Table 90: RPO targets and compliance plan approved by the Commission for FY 2021-22 (MU) ................... 116
Table 91: Employee Expenses submitted by Petitioner for FY 2021-22 (INR Crore) .......................................... 118
Table 92: Computation of CPI Inflation (%) ........................................................................................................... 119
Table 93: Employee Expenses approved by Commission for FY 2021-22 (INR Crore) ...................................... 119
Table 94: A&G Expenses submitted by Petitioner for FY 2021-22 (INR Crore) ................................................. 120
Table 95: A&G Expenses approved by Commission for FY 2021-22 (INR Crore) .............................................. 120
Table 96: R&M expenses submitted by Petitioner for FY 2021-22 (INR Crore) ................................................. 120
Table 97: Computation of WPI Inflation (%) .......................................................................................................... 121
Table 98: R&M Expenses approved by Commission for FY 2021-22 (INR Crore) .............................................. 121
Table 99: O&M Expenses approved by Commission for FY 2021-22 (INR Crore) .............................................. 121
Table 100: Capital Expenditure and Capitalization proposed by the Petitioner for FY 2021-22 (INR Crore) .122
Table 101: Capital Expenditure and Capitalization approved by the Commission for FY 2021-22 (INR Crore)
....................................................................................................................................................................................122
Table 102: Analysis of GFA and capitalization for the control period (FY 2019-20 to FY 2021-22) .................122
Table 103: GFA addition approved by the Commission (INR Crore) for FY 2021-22.........................................124
Table 104: Normative Loan addition approved by the Commission for FY 2021-22 (INR Crore) ....................124
Table 105: Normative Equity addition approved by the Commission for FY 2021-22 (INR Crore)..................124
Table 106: Depreciation as submitted by the Petitioner for FY 2021-22 (INR Crore) ........................................124
Table 107: Depreciation Rate (%) ............................................................................................................................126
Table 108: Depreciation approved by Commission for FY 2021-22 (INR Crore) ...............................................126
Table 109: Interest on loan approved by Commission for FY 2021-22 (INR Crore).......................................... 128
Table 110: Return on Equity as submitted by the Petitioner for FY 2021-22 (INR Crore) .................................129

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 8
DNH Power Distribution Corporation Limited (DNHPDCL)
Table 111: RoE approved by Commission for FY 2021-22 (INR Crore)............................................................... 130
Table 112: Interest on Security Deposits approved by Commission for FY 2021-22 (INR Crore) ..................... 131
Table 113: Interest on Working Capital submitted by the Petitioner for FY 2021-22 (INR Crore) .................... 132
Table 114: Interest on Working Capital approved by Commission for FY 2021-22 (INR Crore) ...................... 133
Table 115: Income Tax approved by Commission for FY 2021-22 (INR Crore) ..................................................134
Table 116: Non -tariff Income approved by Commission for FY 2021-22 (INR Crore) ......................................136
Table 117: Aggregate Revenue Requirement approved by Commission for FY 2021-22 (INR Crore) ..............136
Table 118: Revenue at existing tariff computed by Commission for FY 2021-22 (INR Crore) ........................... 137
Table 119: Standalone Revenue Gap/ (Surplus) approved at existing tariff for FY 2021-22 (INR Crore) .......138
Table 120: Cumulative Revenue Gap/ (Surplus) submitted by Petitioner (INR Crore) .................................... 140
Table 121: Standalone Revenue Gap/ (Surplus) determined by Commission at existing tariff (INR Crore) ... 141
Table 122: Consolidated Revenue Gap/ (Surplus) determined by Commission at existing tariff (INR Crore) 141
Table 123: Retail Tariff proposed by Petitioner for FY 2021-22 ...........................................................................142
Table 124: Existing and Approved Tariff for FY 2021-22 ..................................................................................... 147
Table 125: Revenue from Approved Retail Tariff for FY 2021-22 ....................................................................... 148
Table 126: Tariff increase/decrease approved by Commission for FY 2021-22..................................................149
Table 127: Cumulative revenue Gap/ (Surplus) at approved Tariff for FY 2021-22 ..........................................149
Table 128: Additional Surcharge submitted by Petitioner for FY 2021-22 .......................................................... 151
Table 129: Additional Surcharge approved by Commission for FY 2021-22 ...................................................... 152
Table 130: Allocation of ARR between Wheeling and Retail Supply as submitted by Petitioner for FY 2021-22
.................................................................................................................................................................................... 152
Table 131: Parameters assumed by Petitioner for voltage wise allocation of wheeling charges ....................... 153
Table 132: Wheeling charges proposed by Petitioner for FY 2021-22.................................................................. 153
Table 133: Allocation matrix approved by Commission for FY 2020-21 ............................................................. 154
Table 134: Parameters assumed for voltage wise allocation of wheeling charges ............................................. 154
Table 135: Wheeling Charges approved by Commission for FY 2021-22 ............................................................ 155
Table 136: Cross-subsidy Surcharge for FY 2021-22 submitted by Petitioner .................................................... 155
Table 137: Voltage Wise Losses considered by the Commission ........................................................................... 155
Table 138: Energy Input at each voltage level (MU) ............................................................................................. 155
Table 139: Parameters used for allocation of fixed costs ...................................................................................... 156
Table 140: Voltage Wise Cost of Supply (VCoS) ..................................................................................................... 156
Table 141: Cross-Subsidy Surcharge approved by the Commission for FY 2021-22 .......................................... 156
Table 142: Rapproved determined by Commission for FY 2021-22 ...........................................................................162
Table 143: Tariff Schedule for FY 2021-22 ..............................................................................................................166
Table 144: Applicability of Tariff Schedule for FY 2021-22 ................................................................................... 167
Table 145: Schedule of Miscellaneous Charges for FY 2020-21 ............................................................................170
Table 146: List of participants in Public Hearing .................................................................................................. 172

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 9
DNH Power Distribution Corporation Limited (DNHPDCL)
List of abbreviations
Abbreviation Full Form
A&G Administrative and General
ACoS Average Cost of Supply
Act The Electricity Act, 2003
APR Annual Performance Review
ARR Aggregate Revenue Requirement
ATE Appellate Tribunal of Electricity
BPL Below Poverty Line
CAGR Compound Annualized Growth rate
Capex Capital Expenditure
CEA Central Electricity Authority
CERC Central Electricity Regulatory Commission
CGS Central Generating Stations
COD Commercial Operation Date
Cr Crores
Discom Distribution Company
DNHPDCL DNH Power Distribution Corporation Limited
DSM Deviation Settlement Mechanism
EA 2003 The Electricity Act, 2003
ED Electricity Department
EHT Extra High Tension
FAR Fixed Asset Register
FPPCA Fuel and Power Purchase Cost Adjustment
FY Financial Year
Gadarwara Gadarwara Super Thermal Power Plant
GFA Gross Fixed Assets
HT High Tension
IEX Indian Energy Exchange Limited
IPP Independent Power Producer
JERC Joint Electricity Regulatory Commission for the state of Goa and Union Territories
JGPP or GGPP NTPC Jhanor –Gandhar Gas Based power plants
KAPS Kakrapar Atomic Power Station
Kawas/KGPP NTPC Kawas Gas Based Power Station
Kharagaon/Khargone Khargone Super Thermal Power Plant
KHSTPP Kahalgaon Super Thermal Power Station
KSTPP Korba Super Thermal Power Station
Lara Lara Super Thermal Power Plant
LT Low Tension
MSTPL 1 Mauda Super Thermal Power Station
MU Million Units
MOD Merit Order Dispatch
MYT Multi Year Tariff
NTPC National Thermal Power Corporation Ltd
O&M Operation and Maintenance

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 10
DNH Power Distribution Corporation Limited (DNHPDCL)
Abbreviation Full Form
PGCIL Power Grid Corporation of India Limited
PLF Plant Load Factor
PLR Prime Lending Rate
POSOCO Power System Operation Corporation Limited
PPA Power Purchase Agreement
R&M Repair and Maintenance
REC Renewable Energy Certificate
RLDC Regional Load Despatch Centre
RoE Return on Equity
RPO Renewable Purchase Obligation
SBI PLR SBI Prime Lending Rate
SECI Solar Energy Corporation of India
SERC State Electricity Regulatory Commission
Sipat Sipat Super Thermal Power Station
SLDC State Load Despatch Center
Solapur or SLP Solapur Super Thermal Power Station
SOP Standard of Performance
TAPS Tarapur Atomic Power Station
T&D Transmission & Distribution Loss
TVS Technical Validation Session
UI Unscheduled Interchange
UT Union Territory
VSTPP Vindhyachal Super Thermal Power Station

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 11
DNH Power Distribution Corporation Limited (DNHPDCL)
Before the

Joint Electricity Regulatory Commission


For the State of Goa and Union Territories, Gurugram

CORAM

Shri. M. K. Goel, Chairperson

Petition No. 37/2020

In the matter of

Approval of true-up of FY 2019-20, Annual Performance Review of FY 2020-21, Aggregate Revenue


Requirements (ARR) and Retail Tariff for FY 2021-22.

And in the matter of

DNH Power Distribution Corporation Limited (DNHPDCL)………………….…….……………………………….Petitioner

ORDER
Dated: 23rd March, 2021

1. This Order is passed in respect of a Petition filed by the DNH Power Distribution Corporation Limited
(DNHPDCL) (herein after referred to as “The Petitioner” or “DNHPDCL” or “The Licensee”) for
approval of True- Up of FY 2019-20, Annual Performance Review of FY 2020-21, Aggregate Revenue
Requirements (ARR) and Retail Tariff for FY 2021-22 before the Joint Electricity Regulatory
Commission (herein after referred to as “The Commission” or “JERC”).

2. The Commission scrutinized the said Petition and generally found it in order. The Commission
admitted the Petition on 8th December, 2020. The Commission thereafter requisitioned further
information/ clarifications on the data gaps observed to take a prudent view of the said Petition. The
Commission also held a Technical Validation Session to determine sufficiency of data and the veracity
of the information submitted. Further, suggestions/comments were invited from the
Public/Stakeholders. Further, due to the COVID-19 pandemic that had adversely impacted the
movement of people as per the guidelines of GoI which had suggested avoiding of travel and gathering
of people as far as possible, the Commission had decided to conduct the Public Hearing virtually. The
virtual Public Hearing was held on 29th January, 2021 and all the Stakeholders/Electricity Consumers
present in the Public Hearing were heard.

3. In order to mitigate the hardship of Electricity Consumers and DISCOMs/EDs in view of nationwide
lockdown due to COVID-19, the Commission had issued SUO MOTU ORDER NO.
JERC/LEGAL/SMP/27/2020 on 10th April, 2020 wherein the Commission provided relief to industrial
and commercial consumers and acknowledged the need for additional working capital requirement by
the Distribution Licensees. Further, the Commission viewed that the lockdown will also impact certain
other parameters of ARR like sales/sales mix, power purchase quantum and cost and revenue. The
Commission opined that it will consider all such additional costs and variations in parameters
appropriately while evaluating the APR of FY 2020-21 and thereafter True-up of FY 2020-21.
Accordingly, the Commission in this Order has considered the impact of lower sales, rebate received in
power purchase cost and some other parameters due to COVID- 19 as part of APR for FY 2020-21.
Further, the Commission will consider the actual impact of COVID- 19 on various parameters of ARR
while carrying out the truing up for FY 2020-21.

4. The Commission based on the Petitioner’s submission, relevant MYT Regulations, facts of the matter
and after proper due diligence has approved the True-up of FY 2019-20, APR of FY 2020-21 and ARR
for FY 2021-22 along with the Retail Tariff for FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 12
DNH Power Distribution Corporation Limited (DNHPDCL)
5. The summary has been provided as follows:

(a) The following table provides ARR, Revenue and gap/(surplus) as submitted by the Petitioner and
approved by the Commission in the True-up of FY 2019-20:

Table 1: Standalone Revenue Gap/ (Surplus) approved for FY 2019-20 (INR Crore)
Approved by
S. No Particulars Petitioner's Submission
Commission
1 Net Revenue Requirement 3,646.81 3,614.28
2 Revenue from Retail Sales at Existing Tariff 3,369.82 3,369.82
3 Net Gap / (Surplus) 276.99 244.46

(b) The following table provides ARR, Revenue and gap/(surplus) as submitted by the Petitioner and
approved by the Commission in the APR of FY 2020-21:

Table 2: Standalone Revenue Gap/ (Surplus) approved for FY 2020-21 (INR Crore)
Approved by
S. No Particulars Petitioner’s submission
Commission
1 Annual Revenue Requirement 2,861.15 2,752.29
2 Revenue from sale of power 2,843.02 2,872.78
3 Revenue from Surplus Power Sale 18.22 0.00
4 Revenue from FPPCA 46.09 72.39
5 Total Revenue 2,907.33 2,945.17
6 Revenue Gap/(Surplus) (46.18) (192.88)

(c) The following table provides ARR, Revenue and gap/(surplus) as submitted by the Petitioner and
approved by the Commission for FY 2021-22:

Table 3: Standalone Revenue Gap/ (Surplus) approved for FY 2021-22 (INR Crore)
Approved by
S. No Particulars Petitioner’s submission
Commission
1 Net Revenue Requirement 3,289.01 3,379.76
2 Revenue from Retail Sales at approved Tariff 3,440.39 3,340.08
2 Revenue Gap / (Surplus) (151.38) 39.68

(d) Accordingly, the following table provides the cumulative revenue gap/ (surplus) at approved tariff
at the end of FY 2021-22:

Table 4: Cumulative Revenue Gap/ (Surplus) approved by Commission (INR Crore)


S. No. Particulars Formula FY 2019-20 FY 2020-21 FY 2021-22
a Opening Gap/ (Surplus) (100.14) 146.43 (42.08)
b Add: Gap/ (Surplus) 244.46 (192.88) 39.68
c Closing Gap/ (Surplus) c=a+b 144.32 (46.45) (2.40)
d Average Gap/ (Surplus) d=(a+c)/2 22.09 49.99 (22.24)
e Rate of Interest 9.55% 8.75% 8.00%
f Carrying/Holding cost f=d*e 2.11 4.37 (1.78)
g=f+c
g Closing Gap/ (Surplus) 146.43 (42.08) (4.18)

(e) The average decrease in the retail tariff now approved by the Commission vis-à-vis tariff approved
for FY 2020-21 vide Order dated May 18, 2020 is 5.53%. However, the effective tariff reduction
considering the FPPCA paid by the consumers during FY 2020-21, works out to be 7.93%.

(f) The Commission has approved the Average Billing Rate (ABR) for FY 2021-22 as INR 5.11/kWh as
against the approved Average Cost of Supply (ACoS) of INR 5.17/kWh.

(g) This Order shall come into force with effect from 1st April, 2021 and shall, unless amended or
revoked, continue to be in force till further orders of the Commission.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 13
DNH Power Distribution Corporation Limited (DNHPDCL)
6. The licensee shall publish the Tariff Schedule and salient features of Tariff as determined by the
Commission in this Order within one week of receipt of the Order in three daily newspapers in the
respective local languages of the region, besides English, having wide circulation in their respective
areas of supply and also upload the Tariff Order on its website.
7. Ordered accordingly. The attached documents giving detailed reasons, grounds and conditions are
integral part of this Order.

Sd/-
(M.K. Goel)
Chairperson

Place: Gurugram
Date: 23rd March, 2021

Certified Copy

(Rakesh Kumar)
Secretary

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 14
DNH Power Distribution Corporation Limited (DNHPDCL)
Introduction Joint Electricity Regulatory Commission (JERC)

1. Chapter 1: Introduction

About Joint Electricity Regulatory Commission (JERC)


In exercise of powers conferred by the Electricity Act 2003, the Central Government constituted a Joint
Electricity Regulatory Commission for all the Union Territories except Delhi to be known as the “Joint
Electricity Regulatory Commission for the Union Territories” vide notification no. 23/52/2003-R&R dated May
2, 2005. Later with the joining of the State of Goa, the Commission came to be known as “Joint Electricity
Regulatory Commission for the State of Goa and Union Territories” (hereinafter referred to as “the JERC” or
“the Commission”) vide notification no. 23/52/2003-R&R (Vol. II) dated May 30, 2008.

JERC is a statutory body responsible for regulation of the Power Sector in the State of Goa and the Union
Territories of Andaman & Nicobar Islands, Lakshadweep, Chandigarh, Dadra & Nagar Haveli and Daman & Diu
and Puducherry, consisting of generation, transmission, distribution, trading and use of electricity. Its primary
objective includes taking measures conducive to the development of the electricity industry, promoting
competition therein, protecting interest of consumers and ensuring supply of electricity to all areas.

About Dadra and Nagar Haveli


Dadra and Nagar Haveli (hereinafter referred to as “DNH”) is spread over 491 sq. km, has 72 villages with a
population of 3,42,853 as per Census 2011. The natural attractions of this region have made it a popular tourist
destination in the Western region of India. Additionally, due to liberalized policies of Central Government of tax
benefits, the UT has also developed into a highly industrialized area.

The rapid development of the DNH has led to a tremendous increase in the demand for power. Currently, ~97%
of total sales are to HT and LT industrial consumers. The present peak demand of DNH is 835 MW (As of
December, 2020). DNH has also achieved 100% electrification which further contributes to the increasing
demand for power.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 15
DNH Power Distribution Corporation Limited (DNHPDCL)
Introduction Joint Electricity Regulatory Commission (JERC)

DNH Power Distribution Corporation Ltd.


Dadra & Nagar Haveli Power Distribution Corporation Limited (hereinafter referred to as “DNHPDCL” or
“Utility”) was created from the erstwhile Electricity Department of Dadra & Nagar Haveli (ED-DNH) and
started its operation from April 1, 2013. It is a distribution licensee engaged in distribution of electricity in
Dadra & Nagar Haveli.

The key duties being discharged by DNHPDCL are:

• Laying and operating of electric line, sub-station and electrical plant that is primarily maintained for
the purpose of distributing electricity in the area of supply of DNHPDCL;
• Arranging, in-coordination with the Generating Company (ies) operating in or outside DNH, for the
supply of electricity required within the DNH and for the distribution of the same in the most
economical and efficient manner;
• Supplying electricity, as soon as practicable to any person requiring such supply, within its competency
to do so under the said Act;
• Preparing and carrying out schemes for distribution and generally for promoting the use of electricity
within the DNH.
DNHPDCL does not have its own generation (except some Solar Generation) and procures power from its
allocation from Central Generating Stations i.e. NTPC, NSPC, EMCO and other IPPs.

Existing Network

The present distribution system of DNHPDCL consists of 36.88 circuit km of 220 kV double circuit (D/C) lines,
279.90 km of 66 kV D/C lines, 833.70 circuit km of 11 kV lines along with 1102 distribution transformers.

At present, DNH gets power from 400/220 kV Vapi Substation of POWERGRID and 400/220 kV Kala
Substation of POWERGRID. DNHPDCL has total sub-transmission capacity of 1000 MVA, including 520 MVA
in Kharadpada and 420 MVA Khadoli sub-stations. The total installed capacity at 66/11 kV sub-stations is 782
MVA.

The details of the transmission and distribution system of DNHPDCL are as follows:

Table 5: Transmission & Distribution System of DNHPDCL


S.
Description UOM Length in Circuit (in km)
No.
1 11 kV Line Km 833.70
2 66 kV Line (Double Circuit) Km 279.90
3 220 kV (Double Circuit) Km 36.88
4 Distribution Transformers Nos. 1102

Multi Year Distribution Tariff Regulations, 2014


The Commission notified the Joint Electricity Regulatory Commission for the State of Goa and Union
Territories (Multi-Year Distribution Tariff) Regulations, 2014 on June 30, 2014 applicable for a three year
Control period starting from FY 2015-16 till FY 2017-18. The Commission subsequently notified the Joint
Electricity Regulatory Commission for the State of Goa and Union Territories (Multi-Year Distribution Tariff)
(First Amendment) Regulations, 2015 on August 10, 2015 shifting the MYT Control Period to FY 2016-17 to FY
2018-19. These Regulations are applicable to all the distribution licensees in the State of Goa and Union
Territories of Andaman & Nicobar Islands, Lakshadweep, Chandigarh, Dadra & Nagar Haveli & Daman & Diu
and Puducherry.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 16
DNH Power Distribution Corporation Limited (DNHPDCL)
Introduction Joint Electricity Regulatory Commission (JERC)

Multi Year Tariff Regulations, 2018


The Commission notified the Joint Electricity Regulatory Commission for the State of Goa and Union
Territories (Generation, Transmission and Distribution Multi Year Tariff) Regulations, 2018 on August 10,
2018. These Regulations are applicable in the 2nd MYT Control Period comprising of three financial years from
FY 2019- 20 to FY 2021-22. These Regulations are applicable to all the generation companies, transmission and
distribution licensees in the State of Goa and Union Territories of Andaman & Nicobar Islands, Lakshadweep,
Chandigarh, Dadra Nagar Haveli & Daman and Diu and Puducherry.

Approval of Business Plan for 2nd MYT Control Period


In accordance with the Regulation 8.1 of the JERC MYT Regulations, the Petitioner filed the Petition for
approval of Business Plan for 2nd Multi-Year Control Period from FY 2019-20 to FY 2021-22 on August 31,
2018. The Commission issued the Business Plan Order for the MYT Control Period (hereinafter referred to as
‘Business Plan Order’) on November 5, 2018.

Multi Year Tariff Order for 2nd MYT Control Period


In accordance with the Regulation 9.1 of the JERC MYT Regulations, the Petitioner filed the Petition for
approval of True-up of FY 2017-18, Annual Performance Review for FY 2018-19, Aggregate Revenue
Requirements (ARR) for 2nd MYT Control Period (FY 2019-20 to FY 2021-22) and Determination of Retail
Tariff for FY 2019-20 (MYT Petition). The Commission issued the Order on MYT Petition for Control Period
(hereinafter referred to as ‘MYT Order’) on May 20, 2019.

Approval of True Up for FY 2018-19, APR for FY 2019-20 and


ARR & Tariff for FY 2020-21
In accordance with the Regulation 11 of the JERC MYT Regulations, 2018 the Petitioner filed the Petition for
approval of True-up of FY 2018-19, Annual Performance Review for FY 2019-20, Aggregate Revenue
Requirements (ARR) for FY 2020-21 and Retail Tariff for FY 2020-21. The Commission issued the Order on
this Petition on May 18, 2020.

Filing and Admission of the Present Petition


The present Petition was admitted on December 8, 2020 and was marked as Petition no. 37/2020. The
Commission and the Petitioner subsequently uploaded the Petition on their respective websites.

Interaction with the Petitioner


A preliminary scrutiny/analysis of the Petition was conducted and certain deficiencies were observed.
Accordingly, deficiency notes were issued to the Petitioner. Further, additional information/clarifications were
sought from the Petitioner as and when required. The Commission and the Petitioner also discussed various
concerns of the Petitioner and key data gaps, which included retail sales, revenue from retail tariff,
capitalization, tariff proposal etc. The Petitioner submitted its response on the issues through various
letters/emails.
The Commission conducted the Technical Validation Session (TVS) with the Petitioner at the Commission’s
office in Gurugram, during which the discrepancies in the Petition were conveyed and additional information
required by the Commission was sought. Subsequently, the Petitioner submitted replies to the issues raised in
this session and provided documentary evidence to substantiate its claims regarding various submissions. The
following table provides the list of interactions with the Petitioner along with the dates:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 17
DNH Power Distribution Corporation Limited (DNHPDCL)
Introduction Joint Electricity Regulatory Commission (JERC)

Table 6: List of interactions with the Petitioner


S. No Subject Date
1 Issuance of First Discrepancy Note December 16, 2020
2 Reply received from Petitioner January 05, 2021
3 Technical Validation Session (TVS) with Petitioner at JERC Office January 12, 2021
4 Issuance of Second Deficiency Note January 14, 2021
5 Reply received from Petitioner on queries raised during TVS February 20, 2021
6 Public Hearing January 29, 2021

Notice for Public Hearing


Public notices were published by the Petitioner for inviting suggestions/comments from stakeholders on the
Tariff Petition details of which are given below:

Table 7: Details of Public Notices published by the Petitioner


S. No. Date Name of Newspaper Place of Circulation
1 December 31, 2020 Nishpaksha Jansansar, Hindi Silvasa
2 January 01, 2021 Janadesh, Gujarati Silvasa

The Public Notice was also uploaded on the Petitioner’s website.

The Commission also published Public Notices in the leading newspapers as tabled below, giving due
intimation to the stakeholders, consumers and the Public at large about the Virtual Public Hearing conducted
by the Commission on January 29, 2021 from 11 AM:

Table 8: Details of Public Notices published by the Commission


S. Date Name of Newspaper Place of Circulation
No.
1 December 29, 2020 Indian Express, English Ahmedabad
2 December 29, 2020 Gujarat Samachar, Gujarati Surat
3 December 29, 2020 Nishpaksha Jansansar , Hindi Silvassa
4 December 29, 2020 Samana Times, Hindi Silvassa
5 January 24, 2021 Indian Express, English Ahmedabad
6 January 24, 2021 Gujarat Samachar, Gujarati Surat
7 January 24, 2021 Nishpaksha Jansansar, Hindi Silvassa
8 January 24, 2021 Samana Times, Hindi Silvassa

The Public Notice was also uploaded on the Commission’s website.

Public Hearing
The COVID-19 pandemic has adversely impacted the movement of people as per the guidelines of GoI. These
guidelines have also suggested avoiding of travel and gathering of people as far as possible. In view of above,
the physical conduct of proceedings by the Commission was not possible. So, The Commission deemed it is
necessary to provide an access to all the stakeholders by conducting proceedings remotely, by the use of audio
and video enabled hearings in the matters of Petition submitted by Electricity Department of Daman & Diu
(EDDD). Therefore, the Commission has decided that the comments/suggestions of the stakeholders need to
be heard virtually through video conferencing for seeking their opinion.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 18
DNH Power Distribution Corporation Limited (DNHPDCL)
Introduction Joint Electricity Regulatory Commission (JERC)

Accordingly, the Virtual Public Hearing was held on January 29, 2021 from 11 AM to discuss the issues, if any,
related to the Petition filed by the Petitioner. The issues and concerns raised by the stakeholders in writing and
as voiced by them during the Public Hearing have been examined by the Commission. The names of the
stakeholders who attended the Public Hearing are provided in Annexure-I. The major issues discussed, the
responses of the Petitioner thereon and the views of the Commission have been summarized in Chapter 2 of this
Order.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 19
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

2. Chapter 2: Summary of
Suggestions/Comments received,
Response from the Petitioner and the
Commission’s Views

Regulatory Process
On admitting the Petition, the Commission directed the Petitioner to make copies of the Petition available to
the Public, upload the Petition on its website and also publish the same in the newspapers in an abridged form
duly inviting comments from the Public as per the provisions of the JERC MYT Regulations, 2018.

The Virtual Public Hearing was held on January 29, 2021 from 11 AM onwards on Petition for the True-up of FY
2019-20, APR of FY 2020-21 and Aggregate Revenue Requirements (ARR) for FY 2021-22. During the Public
Hearing, a few of the stakeholders who had submitted their comments in writing also presented their views in
person before the Commission. Other participants from the general Public, who had not submitted written
comments earlier, were also given an equal opportunity to present their views/suggestions in respect to the
Petition.

Suggestions/ Comments, Response of the Petitioner and


Commission’s Views
The Commission is appreciative of the efforts of various stakeholders in providing their
suggestions/comments/observations to make the Electricity Distribution Sector responsive and efficient. The
Commission has noted the concerns of all the stakeholders and has tried to address them to the extent possible
in the Chapters on Tariff Design and Directives. Relevant observations have been suitably considered by the
Commission while finalizing the Tariff Order. The submissions of the stakeholders, response of the Petitioner
and views of the Commission are summarized below:

2.2.1. True up of FY 2019-10


2.2.1.1. Return on Equity

Stakeholder’s Comment:

In the ARR Petition, table 12 (page no. 26), Opening equity is mentioned as INR 135.71 Crore instead of INR
100.08 Cr which was approved in True up of FY 2018-19 as closing equity. Further the petitioner has claimed
unjustified additional RoE of INR 17.11 Cr resulting in high return on equity.

Petitioner’s Response:

As per the JERC (Multi Year Tariff) Regulations, 2018, DNHPDCL is entitled for a Return on Equity (RoE). As
per the Regulation 26, the prescribed Debt to Equity Ratio is 70:30 and the equity on the capital assets to be
computed as 30% of capitalized assets. Accordingly, the return on equity is to be allowed on the basis of equity
deployed in the business. The closing Gross Fixed Assets till 31.03.2019 has been approved by the Commission
as Rs. 452.36 crore and accordingly, the 30% equity as Rs. 135.71 crore has been considered for the
computation of return on equity as per the Regulation.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 20
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

Commission’s View:

The Commission has noted the concern of the stakeholders and the submission of the Petitioner. The
Commission informs the Stakeholders that for true up of FY 2019-20, as shown in Section 3.15 the Opening
equity of FY 2019-20 have been taken as closing equity of FY 2018-19.

2.2.1.2. Interest on finance charges

Stakeholder’s Comment:

Normative numbers are used for future projections/estimation where actual expense incurred details cannot
be available. Similar methodology must not be used for true up. The interest of INR 2.46 Cr on normative loan
of INR 10.13 Cr is overstating of costs and results in overestimation of tariff.

Petitioner’s Response:
DNHPDCL submitted that the interest and finance charges have been considered on a normative basis. The
rate of interest has been considered equal to the SBI PLR as on 1st April, 2019 plus 100 basis points.

Commission’s View:

As per JERC MYT Regulations, 2018, the Petitioner is entitled to interest on loans on normative basis
notwithstanding that the Petitioner has not taken any loan from any outside agency or has exceeded the loan
worked out on normative basis. As DNHPDCL has funded the entire capital expenditure through equity. The
Commission instead of allowing Return on Equity on entire capitalization amount has allowed Return on
Equity on 30% of total capitalization amount and has considered balance 70% as normative loan. Accordingly,
the Commission has allowed normative interest on loan as per SBI MCLR + 100 bps which is based on the
provisions of the JERC MYT Regulations, 2018.

2.2.1.3. Non-Tariff Income

Stakeholder’s Comment:

In ARR Petition for FY 2021-22, table 16, at page no 29, Non-Tariff income claimed is INR 8.22 Cr. However,
in balance sheet other income is INR 42.65 Cr.

Petitioner’s Response:

DNHPDCL submitted that as per the MYT Regulations, 2018, interest income on own fund and delayed
payment surcharge are not required to be considered as non-tariff income. As such, said observation is not
proper and against the applicable JERC Regulations. Further, other operating income of Rs. 5.57 Crore has
been included in the non-tariff income for the FY 2019-20 as per the pervious pattern of practice adopted by
the Commission.

Commission’s View:
The Commission has approved the Non-Tariff Income for FY 2019-20 considering the Regulation 64 of the
JERC MYT Regulations, 2018, as discussed in detail in Section 3.21 of this Order.

2.2.1.4. Income Tax

Stakeholder’s Comment:
In ARR Petition for FY 2021-22, table 14 on page 28, Income tax is INR 2.63 Cr. If corporation is in loss how
expenditure on income tax is possible.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 21
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

DNHPDCL has paid INR 2.63 Cr of income tax in FY 2019-20 while in true-up it has shown a gap of INR
180.51 Cr. This proves that true up doesn’t objectively bring out the financial performance and has many
provisions of undue overstating of expenses. It is requested to the Commission to critically view the systemic
deficiencies in true up process and take corrective measure.
Petitioner’s Response:
DNHPDCL submitted that income tax liability under the applicable income tax is determined as per the
normal provision of taxation and also as per special provision of taxation (i.e. Minimum Alternative Tax).
Moreover, it may also be noticed that separate books of accounts / records is required to be kept in compliance
to the provisions of Income Tax Act, Companies Act and regulatory regime. Further, it may also be noticed
under the Income Tax Act that abnormally higher depreciation is allowed in initial years, whereas, in the
Companies Act / regulatory requirement depreciation is allowed on lesser rate (i.e. useful life) and this result
into difference in between books’ profit and taxable profits for discharge of tax liability on year to year basis.
There is no co-relation between income tax liability and deficit being carried in the regulatory books. Hence,
the said observation is not proper.
The Corporation has paid the income tax of Rs. 2.63 crore and the proof of the payment of income tax has also
been submitted to the Commission.
Commission’s View:

The Commission has noted the concern of the stakeholders and submission of the Petitioner. The Commission
informs the Stakeholders that the approval of Income-Tax has been done considering the JERC MYT
Regulations, 2018 and after proper scrutiny of proofs submitted by the petitioner. The detailed analysis may be
seen in Section 3.19 of this Tariff Order.

2.2.1.5. Interest on Working Capital

Stakeholder’s Comment:
In ARR Petition for FY 2021-22, Table 11, petitioner included receivables of two months to compute Interest on
working capital which is high as consumers in the DNH district pay their dues by 20th day of succeeding
month. The receivables allowed calculating total working capital must be only for 1 month.
Further, INR 53.27 Cr of interest on working capital is arrived on normative basis and not on actual basis. The
petitioner has rarely relied on debt financing for its operational needs resulting in nil expense as interest
expense on working capital. The interest on working capital must be based on actual incurrence basis as
normative basis causes unreasonable and undue overstatement of expenses which leads to over estimation of
tariff.
Petitioner’s Response:
DNHPDCL has computed the Interest on Working Capital on principles outlined by the Commission in the
JERC (Multi Year Tariff) Regulations, 2018. The tariff principles have been outlined after following the due
process and further the interest on working loan in electricity business is allowed as per the provision
contained in respective Regulations (i.e. CERC / JERC / State Regulations). Hence, it is requested to allow the
interest on working capital for the FY 2019-20 as submitted in the Tariff Petition, which has been computed as
per the applicable JERC regulations.
Commission’s View:
As per the JERC MYT Regulations, 2018, the Petitioner is entitled to interest on working capital on normative
basis computed in accordance with Regulation 52.1 of the JERC MYT Regulations, 2018. The Regulations is
reproduced as follows:

“52. Norms of Working Capital for Distribution Wires Business

52.1 The Distribution Licensee shall be allowed interest on the estimated level of working capital for the
Distribution Wires Business for the Financial Year, computed as follows:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 22
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

(c) Receivables equivalent to two (2) months of the expected revenue from charges for use of distribution
wires at the prevailing tariff.

…..”

Hence the Interest on Working Capital is computed by the Commission in accordance with the provisions of
the JERC MYT Regulations, 2018.

2.2.1.6. Revenue from sale of power

Stakeholder’s Comment:
In Annual accounts of FY 2019-20 the revenue earned from sale of power is INR 3,384.58 and not INR
3,369.82. The Commission should approve INR 3384.58 Cr as revenue from sale of power.
Petitioner’s Response:
The said difference is on account of deduction of revenue from sale of power through exchange, Deviation
settlement mechanism receipts and Security constrained Economic dispatch (SCED NLDC) Income amounting
to INR 13.50 Crore from the purchase cost and further non consideration of rebate to consumers of INR 1.26
crore. The said practice is being followed as per the previous pattern. The total of above two figures is INR
14.76 crore. Hence, the said observation is not proper as the same is not resulting any gain to DNHPDCL.
Commission’s View:
The Commission has noted the Stakeholder’s concern and Petitioner’s submission. The Commission informs
the Stakeholders that instead of adding revenue from Deviation settlement mechanism, SECD Income & sale
through exchange in total revenue, the Commission has deducted such revenue from power purchase cost
approved for FY 2019-20 as detailed in Section 3.8 of this tariff order.

2.2.1.7. Revenue Gap/ Surplus

Stakeholder’s Comment:
Power purchase cost shown by the petitioner includes INR 162 Cr on account of RPO whereas the balance
sheet does not show this expense. Note 17 of the audited accounts shows that there was no liability on account
of RPO whereas the balance sheet does not show this expense.
Petitioner’s Response:
DNHPDCL submitted that under the current Regulations, in true up of any year, the cost incurred on meeting
the RPO compliance by purchasing the REC is allowed on cash basis (i.e. in the year in which the cost has been
incurred by the DNHDPCL). The bills against the purchase of REC in the FY 2019-20 have already been
submitted to the Commission. Hence, the above submission is not proper.
Commission’s View:
The Commission has noted the concern of the stakeholders and submission of the Petitioner. The Commission
informs the Stakeholders that the approval of amount against RPO has been allowed considering the JERC
MYT Regulations, 2018 and after proper scrutiny of proofs submitted by the petitioner.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 23
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

2.2.2. Annual Performance Review of FY 2020-21


2.2.2.1. Distribution Losses

Stakeholder’s Comments

It is appreciable that DNHPDCL has made effort to reduce the distribution losses to 3.47% for FY 2019-20.
However, the Petitioner for FY 2020-21 proposed distribution losses as 4.20% when there is a good scope to
further reduce losses to 3.47% for FY 2020-21.

Petitioner’s Response

The matter of Distribution losses is factual statement, hence, does not require any clarification.

Commission’s View

The Commission in the Business Plan Order had approved the distribution loss trajectory for the Second MYT
Control Period (FY 2019-20 to FY 2021-22). The Commission at this stage has considered the distribution loss
of 4.20% as approved in business plan order for DNHPDCL. As Distribution Loss is a controllable factor, the
benefit of lower loss level as compared to target will be shared between the Petitioner and the consumers in
accordance with the Regulations 14.1 of the JERC MYT Regulation, 2018 at the time of truing up of FY 2020-21.

2.2.2.2. Power Requirement

Stakeholder’s Comments

In ARR Petition for FY 2021-22, table 23 on page 35, DHNPDCL estimated the requirement of energy @
5,629.63 MU for FY 2020-21. This requirement has been based on loss @ 4.20% instead of @3.47% which will
result in lesser requirement. Energy requirement should be based on lower losses.

Petitioner’s Response

DNHPDCL has considered the line losses approved by the Commission for the FY 2020-21. Further, the actual
line losses for the FY 2020-21 shall be submitted to the Commission at the time of truing up for the FY 2020-21.

Commission’s View

The Commission in the Business Plan Order had approved the distribution loss trajectory for the Second MYT
Control Period (FY 2019-20 to FY 2021-22). The Commission calculated the energy requirement of FY 2020-21
with 4.20% normative distribution loss as approved in business plan order for DNHPDCL. Energy requirement
for FY 2020-21 has been computed in Section 4.6 of this order. As Distribution Loss is a controllable factor, the
benefit of lower loss level as compared to target will be shared between the Petitioner and the consumers in
accordance with the provisions of the JERC MYT Regulation, 2018 at the time of truing up of FY 2020-21.

2.2.2.3. Power Purchase Cost

Stakeholder’s Comments

As per para 2.2.2.2, if the requirement of energy has come down (by reducing the approved losses to 3.47%
from 4.20%) the power purchase cost will also come down.

Petitioner’s Response

The said matter is factual statement, hence, does not require any clarification.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 24
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

Commission’s View

The Commission in Section 4.7 of this order has computed the power purchase cost and quantum. The power
purchase quantum is based on normative distribution at 4.20% which was approved in Business plan order for
FY 2020-21.

2.2.2.4. Return on equity

Stakeholder’s Comments

In table 33, page 44-45 the opening equity for FY 2020-21 is INR 140.05, whereas it should be INR 104.42.
Petitioner’s opening equity will increase the return on equity since ROE calculated on average equity (Average
of Opening and closing equity).

Petitioner’s Response

As per the JERC (Multi Year Tariff) Regulations, 2018, DNHPDCL is entitled for a Return on Equity (RoE). As
per the Regulations 26 of the MYT Regulations, 2018, the prescribed Debt: Equity Ratio is 70:30 and the equity
on the capital assets to be computed as 30% of capitalized assets. Accordingly, the return on equity is to be
allowed on the basis of equity deployed in the business. Hence, DNHPDCL has arrived at the opening Equity of
INR 140.05 Crore for the FY 2020-21.

Commission’s View

The Commission has noted the concern of the stakeholders and submission of the Petitioner. The Commission
informs the Stakeholders that for APR of FY 2020-21, as shown in Section 4.14 the approved closing equity of
FY 2019-20 have been taken as Opening equity of FY 2020-21.

2.2.2.5. Non-Tariff Income

Stakeholder’s Comments

In table 36, page 46 the claimed non-tariff income is INR 8.22 Cr for FY 2020-21, however, in FY 2019-20
according to the balance sheet NTI is INR 42.65 for FY 2019-20. Hence, Non-tariff income should also increase
for FY 2020-21.

Petitioner’s Response

DNHPDCL submitted that as per the MYT Regulations, 2018, interest income on own fund and delayed
payment surcharge are not required to be considered as non-tariff income. As such, said observation is not
proper and against the applicable JERC Regulations. Further, other operating income of Rs. 5.57 Crore has
been included in the non-tariff income for the FY 2019-20 as per the pervious pattern of practice adopted by the
Commission.

Commission’s View

The Commission has approved the Non-Tariff Income for FY 2020-21 considering the Regulation 64 of the
JERC MYT Regulations, 2018 as discussed in detail in Section 4.19 of this Order.

2.2.2.6. Income Tax

Stakeholder’s Comments

In Tariff Order dated 18th May 2020, the approved income tax was Nil for FY 2020-21. However, the petitioner
has now claimed INR 26.51 Cr under income tax provision. Also, the petitioner has shown net gap of INR

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 25
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

180.51 Cr for FY 2020-21 and hence there is no liability on the petitioner for income tax. The Commission
should disallow this claim.

Further the Petitioner declares revenue gap on the one hand and declares profit before IT department and pay
the income tax. The petitioner then hopes that it can recover this income tax from the consumers.

Petitioner’s Response

DNHPDCL submitted that income tax liability under the applicable income tax is determined as per the normal
provision of taxation and also special provision of taxation (i.e. Minimum Alternative Tax). Moreover, it may
also be noticed that separate books of accounts / records are required to be kept in compliance to the provisions
of Income Tax Act, Companies Act and regulatory regime. Further, it may also be noticed under the Income Tax
Act abnormally higher depreciation is allowed in initial years, whereas, in the Companies Act / regulatory
requirement depreciation is allowed on lesser rate (i.e. useful life) and this result into difference in between
books profit and taxable profits for discharge of tax liability on year to year basis. There is no co-relation
between income tax liability and deficit being carried in the regulatory books. Hence, the said observation is not
proper.

The income tax liability of Rs. 26.21 crore has been determined on the basis of provisions of Income Tax Act
and further an amount of Rs. 15.00 crore has already been paid to income tax department as advance tax for FY
2020-21. The remaining liability of income tax for FY 2020-21 would be paid on or before 15/03/2021 (i.e. last
installment payment due date). The challan of advance tax paid for FY 2020-21 has already been submitted to
Commission. The payment of proof in the matter of income tax liability is already submitted to Commission, in
view of above, it is being requested that the income tax liability of Rs. 26.21 crore as proposed for review of FY
2020-21 may please be allowed by the Commission.

Commission’s View

The Commission has noted the concern of the stakeholders and submission of the Petitioner. The Commission
informs the Stakeholders that the approval of Income-Tax has been done considering the JERC MYT
Regulations, 2018 and after proper scrutiny of proofs submitted by the petitioner.

2.2.2.7. Interest on Working Capital

Stakeholder’s Comment:
In ARR Petition for FY 2021-22, table 32, petitioner included receivables of two months to compute Interest on
working capital which is high as consumers in DNH district pay their dues by 20th day of succeeding month.
The receivables allowed to calculate total working capital must be only for 1 month.
Petitioner’s Response:
DNHPDCL has computed the Interest on Working Capital on principles outlined by the Commission in the
JERC (Multi Year Tariff) Regulations, 2018. The tariff principles have been outlined after following the due
process and further the interest on working loan in electricity business is allowed as per the provision
contained in respective Regulations (i.e. CERC / JERC / State Regulations). Hence, it is requested to allow the
interest on working capital for the FY 2020-21 as submitted in the Tariff Petition, which has been computed as
per the applicable JERC Regulations.

Commission’s View:
As per the JERC MYT Regulations, 2018, the Petitioner is entitled to interest on working capital on normative
basis computed in accordance with Regulation 52.1 of the JERC MYT Regulations, 2018, as shown below:

“52. Norms of Working Capital for Distribution Wires Business

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 26
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

52.1 The Distribution Licensee shall be allowed interest on the estimated level of working capital for the
Distribution Wires Business for the Financial Year, computed as follows:

……

(c) Receivables equivalent to two (2) months of the expected revenue from charges for use of distribution
wires at the prevailing tariff.

…….”

Hence the Interest on Working Capital is computed by the Commission in accordance with the provisions of the
JERC MYT Regulations, 2018.

2.2.3. ARR for FY 2021-22


2.2.3.1. Distribution Losses

Stakeholder’s Comments

For FY 2021-22, the Petitioner has proposed a distribution loss of 4.10% when there is a good scope to further
reduce the losses below 3.47%. Distribution losses on HT/ET & LT industry sales will be negligible. So, the
whole distribution loss, if only projected on remaining non industrial sales, of 4.10% is higher than national
average of distribution loss.

Petitioner’s Response

The said matter is factual statement, hence, does not require any clarification.

Commission’s View

The Commission has noted the submission of the Stakeholders. The Commission acknowledges the fact that the
present loss levels are one of lowest in the country and the Petitioner is putting in constant efforts to maintain
them at a level less than 4%. The Commission directs the Petitioner to make further efforts towards
reduction/maintenance of the same.

2.2.3.2. Power Purchase Cost

Stakeholder’s Comments

The requirement of energy if calculated based on 3.47% loss will be less than the requirement if calculated on
4.10% loss. Subsequently with less requirement the power purchase cost will also go down.

Petitioner’s Response

DNHPDCL has noted the observations regarding Power Purchase Cost. DNHPDCL submitted that it has
considered the distribution losses approved by the Commission for the FY 2021-22. Further, the actual line
losses and Power Purchase Cost for the FY 2021-22 shall be submitted to the Commission at the time of truing
up for the FY 2021-22.

Commission’s View

The Commission in Section 5.7 of this order has computed the power purchase cost and quantum. The power
purchase quantum is based on normative distribution loss at 4.10% which was approved in Business plan Order
for FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 27
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

2.2.3.3. Return on equity

Stakeholder’s Comments

Likewise, previous two years the opening equity for FY 2021-22 is claimed wrongly INR 194.86 whereas it
should be INR 159.23 Cr which has increased the petitioner’s opening equity that in turn will increase the
return on equity since ROE is calculated on average equity (Average of Opening and closing equity).

Petitioner’s Response

As per the JERC (Multi Year Tariff) Regulations, 2018, DNHPDCL is entitled for a Return on Equity (RoE). As
per the Regulations 26 of the MYT Regulations, the prescribed Debt: Equity Ratio is 70:30 and the equity on
the capital assets to be computed as 30% of capitalized assets. Accordingly, the return on equity is to be allowed
on the basis of equity deployed in the business. Hence DNHPDCL has arrived at the opening Equity of Rs.
194.86 Crore for the FY 2021-22.

Commission’s View

The Commission has noted the concern of the stakeholders and submission of the Petitioner. The Commission
informs the Stakeholders that for ARR of FY 2021-22, as shown in Section 5.14 the closing equity of FY 2020-
21 have been taken as Opening equity of FY 2021-22.

2.2.3.4. Non-Tariff Income

Stakeholder’s Comments

The proposed non-tariff income for FY 2021-22 is INR 8.22 Cr however in FY 2019-20 according to the balance
sheet NTI is INR 42.65. So, Non-tariff income for FY 21-22 should increase appropriately wrt that of FY 2019-
20.

Petitioner’s Response

DNHPDCL submitted that as per the JERC MYT Regulations, 2018, interest income on own fund and delayed
payment surcharge are not required to be considered as non-tariff income. As such, the aforesaid observation is
not proper and against the applicable JERC Regulations. Further, other operating income of Rs. 5.57 Crore has
been included in the non-tariff income for the FY 2019-20 as per the pervious pattern of practice adopted by the
Commission.

Commission’s View

The Commission has approved the Non-Tariff Income for FY 2021-22 considering the Regulation 64 of the
JERC MYT Regulations, 2018 as discussed in detail in Section 5.19 of this Order.

2.2.3.5. Income Tax

Stakeholder’s Comments

In ARR petition FY 2021-22 table 67- page 74, the petitioner has claimed INR 26.21 Cr under income tax
provision. However, no income tax was approved for FY 2021-22 in tariff order dated 20th May 2019. So, the
Commission should disallow this claim.

APCPI submitted that petitioner declares revenue gap on the one hand and declares profit before IT deptt. On
the other hand and pays the income tax. The petitioner then hopes that it can recover this income tax from
consumers.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 28
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

Petitioner’s Response

The income tax liability has been proposed to be recovered on the basis of computation of income tax liability as
per the applicable income tax act. There is already liability of income tax in FY 2019-20 and further, the
payment of advance tax to the tune of Rs. 15.00 crore for FY 2020-21. In view of above, DNHPDCL requested
that the income tax liability of Rs. 26.21 crore as proposed for ARR of FY 2021-22 may please be allowed by the
Commission.

Commission’s View

The Commission has noted the concern of the stakeholders and submission of the Petitioner. The Commission
informs the Stakeholders that the approval of Income-Tax has been done considering the Regulation 32 of the
JERC MYT Regulations, 2018. In accordance with regulation 32.2, the Commission approved Nil income tax for
FY 2021-22 since there is no actual income tax paid and the Commission will consider the actual income tax
paid during FY 2021-22 at the time of truing up subject to prudence check.

In this regard, Regulation 32 of MYT Regulations, 2018 stipulates the following:

“32. Tax on Income

32.1 The treatment of tax on income for a Transmission Licensee shall be in accordance with the prevalent
CERC Tariff Regulations.

32.2 The Commission in its MYT Order shall provisionally approve Income Tax payable for each Year of the
Control Period, if any, based on the actual income tax paid, including cess and surcharge on the same, if any,
as per latest audited accounts available for the Distribution Licensee, subject to prudence check.

32.3 Variation between Income Tax actually paid, including cess and surcharge on the same, if any, and
approved, if any, on the income stream of the Licensed business of the Distribution Licensees shall be
reimbursed to/recovered from the Distribution Licensees, based on the documentary evidence submitted at
the time of truing up of each Year of the Control Period, subject to prudence check.

32.4 Under-recovery or over-recovery of any amount from the Consumers on account of such tax having been
passed on to them shall be adjusted every Year on the basis of income-tax assessment under the Income-Tax
Act, 1961, as certified by the statutory auditors. The Distribution Licensee may include this variation in its
truing up Petition:

Provided that tax on any income stream other than the core business shall not be a pass-through component
in tariff and tax on such other income shall be borne by the Distribution Licensee.”

2.2.3.6. Interest on working capital

Stakeholder’s Comments

In Interest on working capital computation for FY 2021-22 petitioner included receivables of two months which
is high as consumers in DNH district pay their dues by 20th day of succeeding month. The receivables allowed
by calculating total working capital must be only for 1 month.

Petitioner’s Response

The said matter is already clarified and the said understanding is not proper.

Commission’s View

As per the JERC MYT Regulations, 2018, the Petitioner is entitled to interest on working capital on normative
basis computed in accordance with Regulation 52.1 of the JERC MYT Regulations, 2018.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 29
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

“52. Norms of Working Capital for Distribution Wires Business

52.1 The Distribution Licensee shall be allowed interest on the estimated level of working capital for the
Distribution Wires Business for the Financial Year, computed as follows:

(c) Receivables equivalent to two (2) months of the expected revenue from charges for use of distribution
wires at the prevailing tariff.

…..”

Hence the Interest on Working Capital is computed by the Commission in accordance with the provisions of the
JERC MYT Regulations, 2018.

2.2.3.7. Computation of Renewable Purchase obligation

Stakeholder’s Comments

The petitioner in its submission while computing the Renewable Purchase Obligation (RPO) has computed the
quantum of RPO for FY 2021-22 by multiplying the RPO as specified by the Commission with the difference of
sale of power within state and power purchase from hydro, thereby not considered the losses within the
distribution area- an approach which is not in line with the JERC (Procurement of Renewable Energy)
Regulations – 2010 which prescribes for the computation of RPO quantum as a percentage of total energy mix
of consumption, excluding Hydro Power in the area of a distribution licensee (which will include the network
losses as well).

Petitioner’s Response

DNHPDCL submitted that the Renewable Purchase Obligation has been computed as per the JERC for the
State of Goa and UTs (Procurement of Renewable Energy) Regulations, 2010. The same basis is being adopted
from the applicability of said regulations. Hence, the submission is not proper.

Commission’s View

Clause 1.1 of JERC (Procurement of Renewable Energy) (Second Amendment), Regulations, 2015, provides as
shown below:

“1.1 Every obligated entity shall purchase electricity from renewable energy sources for fulfillment of a
defined minimum percentage of its total consumption of electricity under the Renewable Purchase
Obligation…”

Further in JERC (Procurement of Renewable Energy) (Third Amendment), Regulations, 2016, the minimum
percentage of the total consumption of electricity that the distribution licensee has to procure under the RPO is
defined for FY 2019-20, FY 2020-21 & FY 2021-22. Accordingly, the Commission for FY 2019-20, FY 2020-21 &
FY 2021-22 has computed the quantum of RPO on basis of above provided Regulations.

2.2.3.8. Computation of Cross Subsidy Surcharge

Stakeholder’s Comments

In petition for FY 2021-22 the Petitioner has proposed a decrease in the energy charges @20 paise/ unit for the
HT category. However, the petitioner while computing the cross subsidy surcharge has considered the Average
Billing Rate (ABR) as approved by the Commission in the Tariff Order for FY 2020-21, which was computed on
the basis of the existing electricity tariff. The Commission is requested to consider the impact of the proposed
decrease in electricity tariff on the computation of ABR while determining the cross subsidy surcharge.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 30
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

Petitioner’s Response

DNHPDCL has noted the observations regarding Cross Subsidy Surcharge. The direction, if any, of the
Commission would be followed by DNHPDCL.

Commission’s View

The Commission has noted the stakeholder’s observations regarding Cross Subsidy Surcharge. The Commission
in Section 7.3 has computed the Cross Subsidy surcharge on the basis of ABR computed after necessary tariff
reduction. Hence the Cross Subsidy surcharge for FY 2021-22 has been computed duly factoring the impact of
approved reduction in electricity tariff.

2.2.3.9. Computation of Additional Surcharge

Stakeholder’s Comments

Petitioner has not conclusively demonstrated the computation of Additional Surcharge (ASC) on stranded
power due to Open Access. The Tariff policy inter-alia provides for a conclusive demonstration of stranded
obligations by the Discom for establishing its claim of Additional Surcharge consequent to open access
contracts. The Commission is requested to allow ASC on stranded power due to Open Access.

Also, petitioner while working out the power purchase, has considered the energy projections on reduced PLF
(as approved by the Commission vide Business Plan Order for FY 2019-20 to FY 2023-24 dated 31st Oct 2018)
which takes into account the average PLF of past years till FY 2018-19. Consequently, this leads to a higher
implication of fixed cost if seen on Rs. /kWh basis which effects per unit additional surcharge. The same fixed
cost per unit will drastically reduce if the PLF projections are considered higher upto normative levels. If fixed
cost is reduced then additional surcharge will also reduce. The Commission is requested to propose
methodology for additional surcharge which is scientific.

Petitioner’s Response

The Additional Surcharge has been computed based on the Joint Electricity regulatory Commission for the
State of Goa and Union Territories (Connectivity and Open Access in Intra-State Transmission and
Distribution) Regulations, 2017. The additional surcharge has been determined on the basis of fixed cost
associated with the power purchase cost obligations.

Commission’s View

The Commission has noted the concerns of the Stakeholders. The methodology adopted by the Commission for
calculation of additional surcharge is detailed in the Chapter 7 of this Order.

2.2.3.10. Power Exchange as a part of Merit Order Despatch

Stakeholder’s Comments

The Commission may consider evolving appropriate framework by which the STOA/Power Exchange rates can
be considered as a part of the merit order of Discom. This proposal will not cause any loss to the Discom in any
circumstances since the bids are cleared on the Power Exchange only when the prices are less than quoted price
and in case if bids are not cleared at the desired rates, they can always call upon the despatches from their tied-
up stations under long term PPA. This will be a win-win situation for the Discom as well as the consumers of
the DNH district.

Petitioner’s Response

DNHPDCL has noted the observations. However, the Commission is empowered to take any decision in this
regard.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 31
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

Commission’s View

The Commission appreciates the concern of the stakeholder and informs that the concept of Merit Order
Dispatch is applicable on power purchased. The petitioner is directed to ensure procuring power
efficiently and follow the Merit Order Despatch.

2.2.3.11. Renewable Power from GTAM market

Stakeholder’s Comments

The Petitioner has projected fulfillment of RPO by way of REC purchase during FY 21-22. In this regard, it is
pertinent to bring to the notice of the Commission that the petitioner can fulfill its pending RPO obligations as
well as the targets in forthcoming years by procuring RE power through the GTAM market also. The
Commission may therefore allow an explicit provision of RE power purchase through GTAM market to the
petitioner.

Petitioner’s Response

DNHPDCL has noted the observations regarding procurement of Renewable power from the G-TAM market.

Commission’s View

The Commission notes the stakeholder’s observation and the petitioner’s reply. The Commission directs
the Petitioner to explore the possibility of procuring Renewable Power for ensuring RPO
compliances.

2.2.4. Other Issues


2.2.4.1. Non Utilization of Interest on Normative loan

Stakeholder’s Comments

The petitioner gets interest on normative loan every year and they cannot spend it unless approved by the
Commission. It is blocking of sum of money every year by charging higher tariffs The Commission should stop
giving interest on normative loan or should direct the petitioner to spend it on the expenses which will
ultimately bring down the tariff.

Petitioner’s Response

The said matter is a factual statement, hence, does not require any clarification.

Commission’s View

The Petitioner is entitled to return on its investments, which includes return on equity and interest on loan. If
the Petitioner is not borrowing funds from outside, a normative portion is considered as loan by the
Commission as per the provisions of the JERC MYT Regulations, 2018 and so, interest on normative loan is
allowed thereon.

2.2.4.2. Sharing of the benefits of savings made by reduction in line loss

Stakeholder’s Comments

In new CERC rules, petitioner can take out 50% of the savings made on account of reduction in line loss. It is an
unjustified proposition as it is a burden on honest consumers. Also, the petitioner can propose higher rate of
line loss and can then reduce it to draw their share.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 32
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

Petitioner’s Response

The said matter is factual statement, hence, does not require any clarification.

Commission’s View

The Commission has noted the concern of the Stakeholders. The Commission has made provision for sharing of
benefits for controllable factors in Regulation 14.1 of the JERC MYT Regulations, 2018. This issue has been
further dealt with in Section 3.22 of this order.

2.2.4.3. Asset by contribution of consumers

Stakeholder’s Comments

No depreciation should be charged over component of consumer contribution on assets. Fixed asset register
should be made public inviting anyone to identify the assets in which they have contributed.

Petitioner’s Response

As per the approved Accounting policy of the corporation, an item of Property acquired on contribution made
by consumer which requires an obligation to provide the electricity to the consumers is recognized at nominal
value of Rs. 1. Hence, the aspect of the calculation of the depreciation on these assets and adjustments thereof
would not arise.

Commission’s View

The Commission notes the concern of the Stakeholder. The Commission informs the petitioner that the issue of
assets created with consumer contribution was taken up by the Commission in tariff order of FY 2018-19 under
a directive. Therein the Commission directed the petitioner to submit detailed scheme wise consumer
contributions. The petitioner submitted the fixed asset register containing of details of assets created from
consumer contribution. The Commission verified the information and was satisfied with the petitioner’s
submission. Hence this direction was dropped in tariff order of FY 2020-21 dated 18th May 2020.

2.2.4.4. Performance Standards reports to be uploaded on website.

Stakeholder’s Comments

The performance standards report which is submitted to the Commission by petitioner should also be made
available to public. The petitioner should upload performance standards report on their website too.

Petitioner’s Response

DNHPDCL has noted the observations regarding Performance Standard Reports.

Commission’s View

The Commission has taken note of the submission made by the Stakeholder and the response thereon by the
Petitioner.

2.2.4.5. Cross Subsidization between EHT/ HT & LT Consumers

Stakeholder’s Comments

The Cross subsidization of power purchase cost is occurring between EHT/HT and LT consumers though both
are industrial consumers with profit motive, which need to be addressed.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 33
DNH Power Distribution Corporation Limited (DNHPDCL)
Stakeholder’s Comments Joint Electricity Regulatory Commission (JERC)

It has been requested to address this long- standing issue of cross- subsidization of power purchase cost
amongst industrial consumers of different voltage levels for fair and judicious levy of tariff.

Petitioner’s Response

The Commission is empowered to take any decision in this regard and the Petitioner craves leave to clarify any
issues that the Commission may desire.

Commission’s View

The Commission has noted the concern of the Stakeholders. The Commission would like to inform that the
Commission determines the tariff based on the submission of the Petitioner, documents places on record and
other relevant factors duly balancing the interest of all stakeholders. The Commission would like to inform that
it has made appropriate efforts and has dealt with the issue of tariff determination and Cross Subsidy in
Chapter 6: Tariff Principles and Design of this Order.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 34
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

3. Chapter 3: True-up for FY 2019-20

Background
The Order on True up of FY 2016-17, Annual Performance Review (APR) of FY 2017-18 and Aggregate Revenue
Requirement (ARR) and tariff for FY 2018-19 was issued on January 30, 2018. The Order on True-up of FY
2017-18, Annual Performance review (APR) of FY 2018-19 and Aggregate Revenue Requirement (ARR) for 2nd
MYT Control Period (FY 2019-20 to FY 2021-22), was issued on May 20, 2019. Subsequently, the Order on
True-up of FY 2018-19, Annual Performance review (APR) of FY 2019-20 and Aggregate Revenue Requirement
(ARR) for FY 2020-21, was issued on May 18, 2020 (hereinafter referred to as the “APR Order” for the purpose
of true-up of FY 2019-20).

As per Regulation 11 of the JERC (Generation, Transmission and Distribution Multi Year Tariff) Regulations,
2018, the review and true-up of revenue and expenses of the Petitioner shall be carried out as follows:

“11. Annual Performance Review, Truing-up and tariff determination during the Control
Period

“11.1 The Generating Company, Transmission Licensee and Distribution Licensee shall be subject to annual
Performance review and truing up of expenses and revenue during the Control Period in accordance with
these Regulations.”

“11.2 The Generating Company, Transmission Licensee and Distribution Licensee shall file an application for
the annual performance review of the current year, truing up of the previous Year or the Year for which the
Audited accounts are available and determination of tariff for the ensuing Year on or before 30th November
of each Year, in formats specified by the Commission from time to time.”

“11.3 The scope of the annual performance review, truing up and tariff determination shall be a comparison of
the performance of the Generating Company, Transmission Licensee or Distribution Licensee with the
approved forecast of Aggregate Revenue Requirement and Expected Revenue from Tariff and Charges and
shall comprise of the following:

a) True-up: a comparison of the audited performance of the Applicant for the Financial Year for which
the true up is being carried out with the approved forecast for such previous Financial Year, subject to
the prudence check
…..”

The Commission now in this Chapter carries out the true-up for FY 2019-20 as per the JERC (Generation,
Transmission & Distribution Multi Year Tariff) Regulations, 2018.

Approach for the True-Up of FY 2019-20


The Petitioner has submitted the audited accounts for FY 2019-20, audited by statutory auditor M/s S. Singhal
& Co. The Commission in this Chapter now carries out the true-up of FY 2019-20 which is the first year of the
second Control Period (FY 2019-20 to FY 2021-22)), in accordance with the principles laid down in the JERC
MYT Regulations, 2018.

Energy Sales
Petitioner’s Submission

The Petitioner has submitted the total quantum of energy sales for FY 2019-20 as 6,288.00 MU as against
approved energy sales quantum of 6,420.75 MU in the APR Order, as shown in the following Table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 35
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Table 9: Energy Sales submitted by the Petitioner for FY 2019-20 (MU)


Approved in APR Petitioner's
S. No Category
Order Submission
1 Domestic 140.11 143.57
2 LIG/ Kutir Jyoti 0.00 10.45
3 Commercial / Non-Domestic 37.00 36.60
4 LT Industrial 224.93 219.44
5 LT Public Water Works 5.04 5.01
6 HT/EHT 6,001.23 5,860.85
7 Agriculture & Poultry 6.62 5.25
8 Public Lighting 3.09 3.06
9 Temp. Supply 2.73 3.75
Total 6,420.75 6,288.00

Commission’s Analysis

In this regard, Regulation 12.1 of the JERC MYT Regulations, 2018 provides:

“12.1 For the purpose of these Regulations, the term “uncontrollable factors” for a Transmission or
Distribution Licensee shall comprise of the following factors, which were beyond the control of the Licensee,
and could not be mitigated by the Licensee:

(a) Force Majeure events:


(b) Change in law;
(c) Variation in the number or mix of Consumers or quantities of electricity supplied to Consumers;
……”

The Commission through a deficiency note asked the Petitioner to submit the Energy audit report for FY 2019-
20. Along with the Energy Audit Report for FY 2019-20, the petitioner submitted that the category wise sales
for the FY 2019-20 submitted as part of the ARR and Tariff Petition for the FY 2021-22 was considered based
upon the data frozen at the time of closing of the FY 2019-20. The data was revalidated to get the slab wise
details of the various consumer categories. During validation of the data some discrepancies came to light and
the same have now been rectified. Accordingly, the petitioner submitted the revised category-wise sales which
are now considered by the Commission.

The Commission had approved the energy sales of 6,420.75 MU in the APR Order, against which actual energy
sales of 6,288.00 MU has been submitted by the Petitioner for FY 2019-20. Accordingly, the Commission
approves the energy sales as submitted by the Petitioner. The table below provides the energy sales approved by
the Commission in the APR Order, the Petitioner’s submission and now trued-up by the Commission:

Table 10: Energy Sales trued-up by the Commission for FY 2019-20 (MU)
Approved in APR Petitioner's Trued-up by
S. No Category
Order Submission Commission
1 Domestic 140.11 154.02 149.62
2 LIG/ Kutir Jyoti 0.00 0.00 0.00
3 Commercial / Non-Domestic 37.00 36.60 36.68
4 LT Industrial (Motive Power) 224.93 219.44 222.59
5 LT Public Water Works 5.04 5.01 5.01
6 HT/EHT 6,001.23 5,860.85 5,860.85
7 Agriculture & Poultry 6.62 5.25 5.73
8 Public Lighting 3.09 3.06 3.06
9 Temp. Supply 2.73 3.75 4.45
Total 6,420.75 6,288.00 6,288.00

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 36
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

The Commission approves Energy Sales of 6,288.00 MU in true-up of FY 2019-20.

Open Access Sales


Petitioner’s Submission

The Petitioner submitted Nil Open Access Sales and Nil Open Access power Purchase for FY 2019-20.

Commission’s Analysis

The Energy Audit Report submitted by the Petitioner specifies Nil Open Access Sales and Open Access Purchase
for FY 2019-20.

Accordingly, the Commission approves Nil Open Access sales and Nil Open Access power
Purchase in the true up of FY 2019-20.

Inter-State Transmission Loss


Petitioner’s Submission

The Petitioner for FY 2019-20 has submitted the Inter-State transmission loss of 3.96%, as against the
approved value of 3.66% in the APR.

Commission’s Analysis

The Petitioner submitted Inter State Transmission loss as 3.96% against 3.66% approved in APR order for FY
2019-20. Through deficiency note the Petitioner was directed to submit the justification for claiming higher
transmission losses. The Petitioner informed that the submitted losses are actual losses.

The Commission has used the Inter-State Transmission losses as provided in Energy Audit report for FY 2019-
20 under ‘Total grid losses in %’ in Table no. 17. The Commission has determined the energy requirement from
tied-up sources in Energy Balance approved in the Section 3.7 of this Order. The energy available from tied-up
source has been considered from the actual energy purchased as approved in Section 3.8 of this Order. The
difference between the two has been considered as the Inter-State transmission loss.

The following table provides the Inter-State transmission loss approved in the APR Order, the Petitioner’s
submission and as approved by the Commission now:

Table 11: Inter-State Transmission Loss for FY 2019-20 (%)


Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Inter-State transmission loss 3.66% 3.96% 3.96%

The Commission approves the Inter-State transmission loss of 3.96% for FY 2019-20.

Distribution Loss
Petitioner’s Submission

The Petitioner has submitted that it has achieved a distribution loss of 3.47% in FY 2019-20 against an
approved loss of 4.30%.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 37
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

Through deficiency note the Commission asked the Petitioner to submit Energy Audit report for FY 2019-20. As
per the Energy Audit Report submitted by the Petitioner, the distribution loss is 3.47%. Accordingly, the
Commission has considered the distribution loss as per the table 17 of the Energy Audit Report.

Since, the Petitioner has achieved a lower distribution loss than approved for the FY 2019-20, the incentive for
the same has to be shared between the Petitioner and the consumers in accordance with the JERC MYT
Regulations, 2018. The calculation of the same has been discussed in detail in the “Section 3.22:
Incentive/Disincentive towards over/under achievement of norms of distribution losses” of this Order.

The following table provides the distribution loss approved in the APR of FY 2019-20, the Petitioner’s
submission and as approved by the Commission now:

Table 12: Distribution loss approved by Commission for FY 2019-20 (%)


Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Distribution Loss 4.30% 3.47% 3.47%

The Commission approves Distribution loss at 3.47% in the true up of FY 2019-20.

Energy Balance
Petitioner’s Submission

The Petitioner has submitted the energy balance as shown in the following table:

Table 13: Energy requirement submitted by the Petitioner for FY 2019-20 (MU)
Petitioner’s
Particulars
Submission
Sales 6288.00
Open Access Sales 0.00
Less: Energy Savings 0.00
Total Sales 6,288.00
Add: Losses 225.85
T&D Losses 3.47%
Energy Required at State Periphery 6,513.85
Add: Sales to common pool consumer 19.42
Add: Sales through IEX 16.81
Less: Own Generation 6.18
Less: Energy Purchased through UI at Periphery 18.95
Less: Purchase from Renewable Sources 0.00
Less: Open Access Purchase 0.00
Less: Power Purchased from Power Exchange 999.80
Total Energy Required at State Periphery 5525.14
Inter State Transmission loss 227.75
Inter State Transmission loss (%) 3.96%
Total Energy to be purchased 5,752.88
Total Energy requirement from tied up sources + UI at generator end + Renewable
6,777.82
sources+ Energy Exchange
Total Energy requirement in UT including Open Access 6,777.82

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 38
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis:
The information submitted by the Petitioner on power purchase quantum, UI over/ under drawl, IEX/ Bilateral
purchase has been studied according to the Energy audit report for FY 2019-20 and accordingly the energy
balance has been derived for FY 2019-20.
The following table provides the energy balance approved in the APR Order, submitted by the Petitioner and
now approved by the Commission:

Table 14: Energy balance approved by Commission for FY 2019-20 (in MU)
Sr. APR Petitioner’s Trued-up by
Particulars Formulae
No. Order Submission Commission
A Sales 6420.75 6288.00 6288.00
B Open Access Sales 0.00 0.00 0.00
C Less: Energy Savings 0.00 0.00 0.00
D Total Sales D=A+B-C 6420.75 6288.00 6288.00
E T&D Losses (%) 4.30% 3.47% 3.47%
F Add: Losses F=G-D 288.50 225.85 225.85
G Energy Required at Periphery G=D/(1-E) 6709.25 6513.85 6513.85
Add: Sales to common pool
H 0.00 19.42 19.42
consumer
I Add: Sales through IEX 0.00 16.81 16.81
J Less: Own Generation 4.93 6.18 6.18
Less: Energy Purchased through UI
K 13.31 18.95 18.95
at Periphery
Less: Purchase from Renewable
L 0.00 0.00 0.00
Sources
M Less: Open Access Purchase 0.00 0.00 0.00
Less: Power Purchased from Power
N 860.44 999.80 999.82
Exchange
Total Energy Required at State O=G+H+I-
O 5830.57 5525.14 5525.14
Periphery J-K-L-M-N
P Transmission loss (%) 3.66% 3.96% 3.96%
Q Transmission loss Q=P-O 221.51 227.75 227.74
Total Energy required to be
R purchased from tied up R=O/(1-Q) 6052.07 5752.88 5752.88
sources at generator end
Total availability from tied up
S 6052.05 5752.88 5752.88
sources at generator end (MU)
T Deficit/ (Surplus) T=R-S 0.02 0.00 0.00

The Commission approves the Total Energy Requirement from tied sources at the generator end
(including own generation) as 5,752.88 MU in the True- Up for FY 2019-20.

Power Purchase Quantum & Cost


Petitioner’s submission:

The Petitioner has submitted that it primarily procures power from the following sources:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 39
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

a) National Thermal Power Corporation Limited (NTPC) stations


b) NSPCL Bhilai
c) Nuclear Power Corporation of India Limited (NPCIL) stations
d) Independent Power Producers

The plant wise details of the power purchase quantum and total power purchase cost incurred has been
provided in the Petition. The Petitioner has submitted that against the power purchase cost of INR 3,495.69
Crore approved by the Commission in the APR Order, it has incurred a cost of INR 3,488.16 Crore.

An amount of INR 0.63 Crore given under the finance charges has been included in the power purchase cost as
the same pertains to carrying cost levied by the generators on power purchase bills due to revision/true up
methodology approved by the CERC. The Petitioner also requested to allow the UI purchase during FY 2019-20
as the same has already been incurred. The total UI over-drawl submitted by the Petitioner is 18.95 MU at a
cost of INR 9.00 Crore.

The power purchase quantum and cost for FY 2019-20, as incurred by the Petitioner has been shown in the
table below:

Table 15: Power Purchase cost submitted by the Petitioner for FY 2019-20
Submitted by Petitioner
Fixed Variable Other Total
S. Energy
Particulars Charges Charges Charges Charges Per Unit
No Units
(INR (INR (INR (INR (INR/kWh)
(MU)
Crore) Crore) Crore) Crore)
A NTPC Stations
KSTPS 366.68 24.47 53.88 0.43 78.78 2.15
KSTPS 3 144.14 19.59 20.75 -0.03 40.31 2.80
VSTPP-I 291.20 24.89 53.34 2.22 80.44 2.76
VSTPP-II 218.05 15.73 38.00 1.68 55.41 2.54
VSTPP- III 251.24 24.84 43.31 1.62 69.77 2.78
VSTPP- IV 305.67 43.66 50.68 1.85 96.18 3.15
KGPP 178.23 49.96 49.10 0.55 99.61 5.59
GGPP 30.97 45.56 9.18 0.32 55.06 17.78
Sipat-I 558.84 72.52 85.65 2.15 160.31 2.87
Sipat-II 220.84 26.30 34.66 0.47 61.44 2.78
Mauda 206.62 49.66 65.34 4.14 119.15 5.77
VSTPS-V 182.78 28.70 34.85 1.30 64.85 3.55
Mauda 2 256.79 57.80 80.92 9.72 148.44 5.78
Solapur 42.40 82.53 14.66 -0.50 96.69 22.80
LARA 104.08 23.92 26.20 0.42 50.54 4.86
Gadarwara 39.07 45.06 13.02 0.15 58.24 14.91
BARH 0.00 0.00 0.00 0.00 0.00 0.00
Kharagaon 25.48 7.89 7.60 0.00 15.49 6.08
Dhuwaran 0.00 0.00 0.00 0.00 0.00 0.00
FSTPS 0.00 0.00 0.00 0.00 0.00 0.00
KhSTPS I 0.00 0.00 0.00 0.00 0.00 0.00
RSTPS 0.00 0.00 0.00 0.00 0.00 0.00
TSTPS 0.00 0.00 0.00 0.00 0.00 0.00
KHSTPP-II 21.62 2.30 4.62 -0.15 6.77 3.13
Subtotal – NTPC 3444.71 645.38 685.77 26.34 1346.10* 3.91
B NSPCL – Bhilai 416.95 115.38 142.35 -5.53 247.13^ 5.93
C NPCIL 397.30 0.00 121.06 0.00 121.06 3.05
KAPS 93.72 0.00 23.80 0.00 23.80 2.54
TAPS 303.58 0.00 97.26 0.00 97.26 3.20
D EMCO Energy 1493.92 471.99 352.87 0.82 825.67 5.53
Total from Tied up
5752.88 1232.75 1302.04 21.62 2,539.96 4.42
sources

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 40
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Submitted by Petitioner
Fixed Variable Other Total
S. Energy
Particulars Charges Charges Charges Charges Per Unit
No Units
(INR (INR (INR (INR (INR/kWh)
(MU)
Crore) Crore) Crore) Crore)
Other Sources
E
Indian E.
0.00
Exchange/Bilateral 999.80 0.00 319.70 319.70 3.20
UI 18.95 0.00 9.00 0.00 9.00 4.75
Solar 6.18 0.00 0.00 0.00 0.00 0.00
Non Solar 0.00 0.00 0.00 0.00 0.00 0.00
Solar REC 0.00 0.00 29.72 0.00 29.72 -
Solar (SECI) 0.00 0.00 0.00 0.00 0.00 -
Wind (SECI) 0.00 0.00 0.00 0.00 0.00 -
Non Solar REC 0.00 0.00 132.79 0.00 132.79 -
Subtotal - Other
0.00 491.21 4.79
Sources 1024.94 0.00 491.21
E Total 6777.82 1232.75 1793.25 21.62 3031.16 4.47
Availability at ED-
F
DNH Periphery
PGCIL CHARGES 431.91
POSOCO 1.09
Reactive charges 0.22
Intra-state
42.59
transmission charges
Less: Rebate received 53.50
Add: Carrying cost
0.63
levied by generators
Add: Change In law-
47.56
GMR
Less: Revenue from Sale
5.73
of Power at exchange
Less: DSM Receipts 3.74
Less: Sale through SECD 4.04
Total Power
G 6,777.82 3,488.16
Purchase cost
* Including INR -11.39 Cr of amount regarding Credit/Debit for URS & RRAS Settlement
^ Including INR -5.07 Cr of amount regarding RRAS Settlement

Commission’s Analysis

Regulation 12.1 of the JERC MYT Regulations, 2018 provides:

“12.1 For the purpose of these Regulations, the term “uncontrollable factors” for a Transmission or
Distribution Licensee shall comprise of the following factors, which were beyond the control of the Licensee,
and could not be mitigated by the Licensee:

(a) Force Majeure events;

(b) Change in law

(c) Variation in the number or mix of Consumers or quantities of electricity supplied to Consumers;

(d) Transmission loss;

(e) Variation in the cost of power purchase due to variation in the rate of power purchase from
approved sources, subject to clauses in the power purchase agreement or arrangement approved by
the Commission;

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 41
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

…”

The Petitioner procures power mainly from NTPC Stations, NPCIL stations, NSPCL Bhilai and IPPs. The
Petitioner submitted the overall power purchase cost as INR 3,488.16 Crore inclusive of transmission cost and
after adjusting revenue due to sale of surplus power and DSM receipts.

The Commission has verified the power purchase quantum and cost as per the monthly station-wise bills
submitted by the Petitioner for each station. The cost has been reconciled with the audited annual accounts of
FY 2019-20. The amount of INR 0.63 Crore pertains to the carrying cost levied by the generators on power
purchase bills due to revision/true up methodology approved by the CERC, which falls under the definition of
uncontrollable factors as per clause 12.1 (b) of the JERC MYT Regulations ,2018 and hence allowed by the
Commission.

The Petitioner has claimed purchase of non-solar REC’s worth INR 132.79 Cr equivalent to 711.69 MU & solar
REC’s worth INR 29.72 Cr equivalent to 109.70 MU. The Commission has verified this purchase of Solar & Non-
solar renewable energy certificates from the audited annual accounts of FY 2019-20.

The Commission verified the petitioner claims of revenue earned from sale to common pool consumers,
Deviation settlement Mechanism receipts & Security constrained Economic dispatch (SCED NLDC) from Note
19 audited balance sheet for FY 2019-20. These revenues are subtracted from the approved power purchase for
FY 2019-20.

The petitioner claimed Power Purchase through UI as 18.95 MU. The Commission verified quantum of power
purchase through UI from energy audit report for FY 2019-20 (Table 17). The Commission has approved the
Power Purchase through UI as per petitioner’s claim.

Further, the Petitioner claimed INR 47.56 Crore under Change in law claims by GMR Warora Energy Limited
(GWEL, formerly EMCO Energy Limited). These claims are based on the multiple orders issued by the Central
Electricity Regulatory Commission (CERC), details for some such orders are provided below:

• CERC Order dated 18/12/2019 in Petition 39/MP/2019 - On Account of coal/railway terminal


surcharge for period July 2018 to September 2019.
• CERC order dated April 02, 2019 in Petition 71/MP/2018 - On account of Evacuation Facility Charges
approved for period December 2017 to March 2019 & May 2019 to December 2019.
• CERC Order dated May 16, 2019 in Petition 284/MP/2018 - On Account of Change in Law during the
Operating Period as per the mechanism provided in the PPA and without any separate mechanism
required to be prescribed.

Accordingly, the Commission verified this amount from the supplementary invoices (issued by GMR to
petitioner) submitted by the Petitioner and observed that the total amount as per invoice is Rs 53.44 Cr. On
enquiry, the petitioner submitted that only INR 47.56 Crore has been released in FY 2019-20 and the same has
been claimed. Accordingly, the Commissions approve INR 47.56 Crore as expenses for change in law claims by
GMR Warora Energy Limited.

The following table provides the summary of the power purchase quantum and the cost approved by the
Commission during FY 2019-20:

Table 16: Power Purchase quantum and cost approved by the Commission for FY 2019-20
Approved by Commission
Fixed Variable Other Total
S. Energy
Particulars Charges Charges Charges# Charges Per Unit
No Units
(INR (INR (INR (INR (INR/kWh)
(MU)
Crore) Crore) Crore) Crore)
A NTPC Stations
KSTPS 366.68 24.47 53.88 0.43 78.78 2.15

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 42
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Approved by Commission
Fixed Variable Other Total
S. Energy
Particulars Charges Charges Charges# Charges Per Unit
No Units
(INR (INR (INR (INR (INR/kWh)
(MU)
Crore) Crore) Crore) Crore)
KSTPS 3 144.14 19.59 20.75 -0.03 40.31 2.80
VSTPP-I 291.20 24.89 53.34 2.22 80.44 2.76
VSTPP-II 218.05 15.73 38.00 1.68 55.41 2.54
VSTPP- III 251.24 24.84 43.31 1.62 69.77 2.78
VSTPP- IV 305.67 43.66 50.68 1.85 96.18 3.15
KGPP 178.23 49.96 49.10 0.55 99.61 5.59
GGPP 30.97 45.56 9.18 0.32 55.06 17.78
Sipat-I 558.84 72.52 85.65 2.15 160.31 2.87
Sipat-II 220.84 26.30 34.66 0.47 61.44 2.78
Mauda 206.62 49.66 65.34 4.14 119.15 5.77
VSTPS-V 182.78 28.70 34.85 1.30 64.85 3.55
Mauda 2 256.79 57.80 80.92 9.72 148.44 5.78
Solapur 42.40 82.53 14.66 -0.50 96.69 22.80
LARA 104.08 23.92 26.20 0.42 50.54 4.86
Gadarwara 39.07 45.06 13.02 0.15 58.24 14.91
BARH 0.00 0.00 0.00 0.00 0.00 0.00
Kharagaon 25.48 7.89 7.60 0.00 15.49 6.08
Dhuwaran 0.00 0.00 0.00 0.00 0.00 0.00
FSTPS 0.00 0.00 0.00 0.00 0.00 0.00
KhSTPS I 0.00 0.00 0.00 0.00 0.00 0.00
RSTPS 0.00 0.00 0.00 0.00 0.00 0.00
TSTPS 0.00 0.00 0.00 0.00 0.00 0.00
KHSTPP-II 21.62 2.30 4.62 -0.15 6.77 3.13
Subtotal – NTPC 3444.71 645.38 685.77 26.34 1346.10* 3.91
B NSPCL – Bhilai 416.95 115.38 142.35 -5.53 247.13^ 5.93
C NPCIL 397.30 0.00 121.06 0.00 121.06 3.05
KAPS 93.72 0.00 23.80 0.00 23.80 2.54
TAPS 303.58 0.00 97.26 0.00 97.26 3.20
D EMCO Energy 1493.92 471.99 352.87 0.82 825.67 5.53
Total from Tied up
E 5752.88 1232.75 1302.04 21.62 2,539.96 4.42
sources
F Other Sources

Indian E.
0.00
Exchange/Bilateral 999.80 0.00 319.70 319.70 3.20
UI 18.95 0.00 9.00 0.00 9.00 4.75
Solar 6.18 0.00 0.00 0.00 0.00 0.00
Non Solar 0.00 0.00 0.00 0.00 0.00 0.00
Solar REC 0.00 0.00 29.72 0.00 29.72 -
Solar (SECI) 0.00 0.00 0.00 0.00 0.00 -
Wind (SECI) 0.00 0.00 0.00 0.00 0.00 -
Non Solar REC 0.00 0.00 132.79 0.00 132.79 -
Subtotal - Other
1024.94 0.00 491.21 0.00 491.21 4.79
Sources
Total 6777.82 1232.75 1793.25 21.62 3031.16 4.47
PGCIL CHARGES 431.91
POSOCO 1.09

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 43
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Approved by Commission
Fixed Variable Other Total
S. Energy
Particulars Charges Charges Charges# Charges Per Unit
No Units
(INR (INR (INR (INR (INR/kWh)
(MU)
Crore) Crore) Crore) Crore)
Reactive charges 0.22
Intra-state
42.59
transmission charges
Less: Rebate received 53.50
Add: Carrying cost
0.63
levied by generators
Add: Change In law-
47.56
GMR-EMCO
Less: Revenue from Sale
5.73
of Power at exchange
Less: DSM Receipts 3.74
Less: Sale through SECD 4.04
Total Power
G 6,777.82 3,488.15
Purchase cost

* Including INR -11.39 Cr of amount regarding Credit/Debit for URS & RRAS Settlement
^ Including INR -5.07 Cr of amount regarding RRAS Settlement
# Other Charges includes ED & Cess on APC/Sales, Energy Charges Revision, ECR Gain Sharing, Insurance charges, Nuclear Liability
Fund, sharing of benefits etc.

The Commission approves power purchase cost of INR 3,488.15 Crore and power purchase
quantum of 6,777.82 MU in the true-up of FY 2019-20.

Renewable Purchase Obligation (RPO)


Petitioner’s Submission

For FY 2019-20, the Petitioner purchased 6.18 MUs of electricity from its own Solar Generation plant and
purchased 821.29 MU (109.60 MU of Solar & 711.69 MU of Non-Solar) equivalent of Renewable Energy
Certificates.

Commission’s Analysis

In this regard, Regulation 1.1 of the JERC for the State of Goa and UTs (Procurement of Renewable Energy)
Regulations, 2010 provides:

“(1.1) Each distribution licensee shall purchase electricity (in kWh) from renewable energy sources, at a
defined minimum percentage of the total consumption of all the consumers in its area during a year.”

Further, the Commission notified the JERC (Procurement of Renewable Energy), (Third Amendment)
Regulations, 2016 on 22nd August, 2016 and revised the RPO targets, according to which the Petitioner had to
purchase 11.50% (Solar-4.70% and Non-Solar-6.80%) of its total consumption (excluding hydro) from
renewable sources for FY 2019-20.

As per the above Regulations for FY 2019-20, the Petitioner had a standalone RPO target of 723.12 MU
quantum of energy comprising of 295.54 MU to be purchased from solar and 427.58 MU to be purchased from
Non Solar. Against the target, the Petitioner has produced 6.18 MU of physical solar power. Further, the
Petitioner has bought Solar & Non-Solar RECs equivalent to 109.60 MUs and 711.69 MUs respectively. So, the
Petitioner could not meet the current year targets of Solar RPO and the cumulative shortfall for Solar and Non-
solar up to FY 2019-20 now stands at 675.33 MUs.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 44
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

The RPO target compliance up to FY 2019-20 has been provided in the following table:

Table 17: Summary of Renewable Purchase Obligation (RPO) for FY 2019-20 (MU)
Sr. Particulars Formulae FY 2017-18 FY2018-19 FY2019-20
No.
A Solar Target 2.50% 3.60% 4.70%
B Non Solar Target 4.20% 5.40% 6.80%
C Total Target C=A+B 6.70% 9.00% 11.50%
D Sales Within UT 5,676.30 6,072.42 6,288.00
RPO Target
E Solar E=D*A 141.91 218.61 295.54
F Non Solar F=D*B 238.40 327.91 427.58
G Total RPO Target G=E+F 380.31 546.52 723.12
RPO Compliance (Actual Purchase)
H Solar 5.23 5.76 6.18
I Non Solar 0.00 0.00 0.00
J Total RPO Compliance
J=H+I 5.23 5.76 6.18
(Actual Purchase)
RPO Compliance (REC Certificate Purchase)
K Solar 0.00 338.68 109.60
L Non Solar 0.00 10.00 711.69
M Total RPO Compliance
M=K+L 0.00 348.68 821.29
(REC Certificate)
RPO Compliance (REC+ Actual)
N Solar N=H+K 5.23 344.44 115.78
O Non Solar O=I+L 0.00 10.00 711.69
P Total RPO Compliance P=N+O 5.23 354.44 827.47

Cumulative Requirement till current year


Q Solar 336.03 554.64 850.18
R Non Solar 976.33 1,304.24 1731.83
S Total S=Q+R 1,312.37 1,858.89 2582.01

Cumulative Compliance till current year


T Solar 126.25 470.69 586.47
U Non Solar 598.52 608.52 1320.21
V Total V=T+U 724.77 1,079.21 1906.68

Net Shortfall in RPO Compliance till current year


V Solar V=Q-T 209.79 83.96 263.71
W Non Solar W=R-U 377.81 695.72 411.62
X Total X=V+W 587.60 779.68 675.33

As mentioned above in S. No. K & L, the Commission approved actual cost of INR 29.72 Crore
for purchase of Solar REC equivalent to 109.60 MUs at an average cost of INR 2.71/unit and INR
132.79 Crore for purchase of Non-Solar REC equivalent to 711.69 MUs at an average cost of INR
1.87/unit.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 45
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Accordingly, the Commission has approved actual cost of INR 162.51 Crore towards compliance
of RPO in the true-up of FY 2019-20 which is already considered as part of Power Purchase
Cost.

Operation & Maintenance Expenses


The Operation & Maintenance Expenses comprises of the Employee Expenses, Administrative and General
Expenses (A&G) and the Repair & Maintenance Expenses (R&M). As per the JERC MYT Regulations, 2018
variation in Expenses is controllable. Regulation 12.2 and Regulation 14 of the JERC MYT Regulation, 2018
states the following:

“12. Uncontrollable and Controllable factors


……
12.2 For the purpose of these Regulations, the term “controllable factors” for a Transmission or Distribution
Licensee shall comprise of the factors which were within the control of the Licensee, shall inter-alia include:

(h) Variation in O&M Expenses, except to the extent of inflation
…”

Therefore, any variation in O&M Expenses is attributable to the Petitioner and is not passed on in the ARR,
other than any cost, which is beyond the control of the Petitioner.

“14. Mechanism for sharing of gains or losses on account of controllable factors

14.1 Approved aggregate gain to the Transmission Licensee or Distribution Licensee on account of
controllable factors shall be shared equally between Licensee and Consumers:

Provided that the mechanism for sharing of gains or losses on account of controllable factors for a Generating
Company shall be as specified in the prevalent CERC Tariff Regulations.

14.2 Approved aggregate loss, if any to the Transmission Licensee or Distribution Licensee on account of
controllable factors shall be on account of the Licensee, and shall not be passed to the Consumers.”

Therefore, any approved gain to the Distribution Licensee on account of controllable factors shall be shared
equally between Licensee and Consumers in accordance with the JERC MYT Regulations, 2018. Further
Regulations 51.6 provides as follows:

“51. Operation and Maintenance (O&M) expenses for Distribution Wires Business

“….

51.6 For the purpose of estimation, the same value of factors – CPIinflation and WPIinflation shall be used for
all Years of the Control Period. However, the Commission shall consider the actual values of the
factors – CPIinflation and WPIinflation during the truing up exercise for the Year for which
true up is being carried out and true up the O&M Expenses for that Year, only to the extent of
inflation.” (Emphasis supplied)

3.10.1. Employee Expenses


Petitioner’s Submission
The actual Employee expenses of INR 12.95 Crore have been incurred against approved expenses of INR 12.83
Crore in the APR Order. The employee expenses comprise of Salaries, Dearness allowance, Bonus, Terminal
benefits in the form of Pension and Gratuity, Leave encashment and staff welfare expenses.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 46
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis
The Commission had approved employee expenses of INR 12.83 Crore in the APR Order. The actual employee
expenses for FY 2019-20 as per audited accounts are INR 12.95 Crore.
In accordance with the clause 51.6 of the JERC MYT Regulations, 2018, the Commission has determined the
revised Normative Employee Expenses for FY 2019-20. The revised normative employee expenses are
calculated based on the approved employee expenses (INR 12.41 Cr) for FY 2018-19 approved in order dated
18th May, 2020 and CPI inflation (7.53%) & actual Gn (Employee growth, i.e., 0%) for the FY 2019-20 with
respect to FY 2018-19. Accordingly, the Commission has determined the revised employee expenses as INR
13.34 Crore for FY 2019-20.
Further, in accordance with the JERC MYT Regulations, 2018, the O&M expenses are controllable expenses.
Hence, the Commission has considered the revised normative Employee Expenses as determined above for FY
2019-20. Accordingly, the employee expenses approved for FY 2019-20 is shown in the table below.

Table 18: Employee Expenses approved by Commission for FY 2019-20 (INR Crore)
Approved in Petitioner's Revised Trued-up by
S. No Particulars
APR Order Submission Normative EE Commission
Employee Expenses
1 12.83 12.95 13.34 13.34
(EE)

The Commission approves Employee Expenses of INR 13.34 Crore in the true-up of FY 2019-20.

3.10.2. Administrative and General (A&G) Expenses

Petitioner’s Submission

The Petitioner has submitted the actual A&G expenses of INR 7.31 Crore against the approved expenses of INR
6.09 Crore in the APR Order.

Commission’s Analysis

A&G expenses mainly comprises of rents, telephone and other communication expenses, professional charges,
conveyance and travelling allowances, etc. As per the audited accounts submitted by the Petitioner, the A&G
expenses for FY 2019-20 are reflected as INR 7.31 Crore, while INR 0.63 Crore, which the Petitioner has
claimed as part of A&G expense is actually the provision for Bad and doubtful debt. Similar to the approach
followed while approving the revised normative Employee expenses the Commission has determined revised
Normative A&G expenses which is based on the approved A&G expenses (INR 5.84 Cr) of FY 2018-19 and
actual CPI Inflation for FY 2019-20 with respect to FY 2018-19. Accordingly, the Commission has determined
the revised A&G expenses as INR 6.28 Crore.
In accordance with the JERC MYT Regulations, 2018, variation in O&M expenses are controllable. Therefore,
the Commission has approved the same revised A&G expenses as approved in above para. Further, bad and
doubtful debt being a separate expenses item as per the JERC MYT Regulations 2018, is dealt with in Section
3.20 of this Order. Accordingly, the A&G expenses approved by the Commission are as follows:

Table 19: A&G Expenses approved by Commission for FY 2019-20 (INR Crore)
S. Approved in Petitioner's Revised Trued-up by
Particulars
No APR Order Submission Normative A&G Commission
Administration & General
1 6.09 7.31 6.28 6.28
Expenses (A&G)

The Commission approves the Administrative & General (A&G) expenses of INR 6.28 Crore in
the true-up of FY 2019-20.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 47
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

3.10.3. Repair & Maintenance Expenses (R&M)

Petitioner’s Submission

Actual R&M expenses of INR 19.50 Crore have been incurred against approved expenses of INR 11.38 Crore in
the APR Order. The Petitioner submitted that Power Load Management of DNHPDCL is higher by 150% as
compared to EDDD and Chandigarh & distribution area of DNHPDCL is greater than both the other utilities.
Also, line length maintained by DNHPDCL is materially higher than as compared to EDDD and Chandigarh.
Accordingly, the R&M expenses should be higher for DNHPDCL as compared to both the other utilities.

Commission’s Analysis

Similar to the approach followed while approving the revised normative Employee expenses the Commission
has determined revised Normative R&M expenses which is based on the approved closing GFA of FY 2018-19,
actual WPI Inflation for FY 2019-20 (1.68%) with respect to FY 2018-19 and ‘K’ factor which was approved in
MYT order dated 20th May, 2019, for the second (FY 20 to FY 22) control period. Accordingly, the Commission
determined the revised R&M expenses as INR 9.34 Crore.

As the O&M expenses are controllable expenses as per the JERC MYT Regulations, 2018, similar to the
approach followed while approving the Employee expenses and A&G expenses above, the Commission approves
the same revised R&M Expenses as approved in above para.

The R&M Expenses approved by the Commission are as follows:

Table 20: R&M Expenses approved by Commission for FY 2019-20 (INR Crore)
Approved in Petitioner's Revised Trued-up by
S. No Particulars
APR Order Submission Normative R&M Commission
Repair & Maintenance
1 11.38 19.50 9.34 9.34
Expenses (R&M)

The Commission approves the Repair & Maintenance (R&M) expenses of INR 9.34 Crore in the
true-up of FY 2019-20.

3.10.4. Total Operation and Maintenance Expenses (O&M)

The following table provides the O&M expenses, approved by the Commission in the APR Order, Petitioner’s
submission and O&M expenses now trued-up by the Commission.

Table 21: O&M Expenses approved by Commission for FY 2019-20 (INR Crore)
S. Approved in Petitioner's Revised Trued-up by
Particulars
No APR Order Submission Expenses Commission
1 Employee Expenses 12.83 12.95 13.34 13.34
Administrative & General
2 6.09 7.31 6.28 6.28
Expenses (A&G)
3 Repair & Maintenance Expenses 11.38 19.50 9.34 9.34
Total Operation &
30.30 39.76 28.96 28.96
Maintenance Expenses

The Commission approves the Operation & Maintenance (O&M) expenses of INR 28.96 Crore in
the true-up of FY 2019-20.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 48
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Gross Fixed Assets (GFA) and Capitalization


Petitioner’s submission

The Petitioner has achieved capitalization of INR 14.48 Crore during the year against INR 5.70 Cr capitalization
approved in the APR Order. The capital expenditure during the same period was INR 42.89 Crore against
approved capital expenditure of INR 128.20 Crore.

Commission’s Analysis:

The Commission observes that the Petitioner has capitalized INR 16.22 Crore as per FAR while the
capitalization approved by the Commission in the APR Order was INR 5.70 Cr. The petitioner further submitted
that out of INR 16.23 Crores, INR 1.66 Crore is pertaining to solar assets of the department (DNHPDCL).
Accordingly, the Commission reduced the INR 1.66 Crore pertaining to solar plant from the total capitalization
of INR 16.23 Crore. Further the Commission also reduced an amount of INR 0.10 Crore pertaining to assets
retired in FY 2019-20 as per FAR.

The Commission accordingly approves the capitalization as shown in the table below:

Table 22: Capitalization approved by Commission for FY 2019-20 (INR Crore)


Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Capital Expenditure 128.20 42.89 42.89
2 Capitalization 5.70 14.48 14.48

The Commission approves capital expenditure and capitalization of INR 42.89 and INR 14.48
Crore respectively in the true-up of FY 2019-20.

Capital Structure
Petitioner’s Submission

The Petitioner has submitted that the entire capital addition has been funded through its own funds. Further,
the Petitioner has also submitted that no assets were created through consumer contribution, nor any grants
were received from the Government during FY 2019-20.

Commission’s Analysis

The JERC MYT Regulations 2018, specify that if the equity actually deployed is more than 30% of the capital
cost, then equity in excess of 30% would be considered as normative loan. Regulation 26.2 of the JERC MYT
Regulations 2018 states the following:

“26.2 For New Projects, the debt-equity ratio as on the Date of Commercial Operation shall be 70:30 of the
amount of capital cost approved by the Commission under Regulation 23, after prudence check for
determination of tariff:

Provided that where equity actually deployed is less than 30% of the capital cost of the capitalised asset, the
actual equity shall be considered for determination of tariff:

Provided also that if the equity actually deployed is more than 30% of the capital cost, equity in excess of 30%
shall be treated as a normative loan for the Licensee for determination of tariff:
……”

In accordance with the JERC MYT Regulations, 2018 the Commission has determined the Capital Structure for
FY 2019-20. The closing GFA approved in FY 2018-19 has been considered as the opening GFA for FY 2019-20.
The opening debt for FY 2019-20 has been considered as closing debt approved in true-up of FY 2018-19.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 49
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

The petitioner has submitted the equity opening balance of INR 135.71 Crore in the True Up of FY 2019-20
instead of approved Closing equity balance for FY 2018-19 which is INR 100.08 Crore. The Commission is
considering the opening equity for FY 2019-20 as per the closing balance of true-up of FY 2018-19.

The addition in debt and equity has been normatively considered as 70% and 30% respectively of the
capitalization during the year in accordance with the JERC MYT Regulations, 2018. Accordingly, the
Commission approves the capital structure for FY 2019-20 as shown in the tables as follows:

Table 23: Funding Plan approved by the Commission for FY 2019-20 (INR Crore)
Approved in APR Petitioner's Trued-up by
S. No Particulars
Order Submission Commission
1 Capitalization 5.70 14.48 14.48
2 Debt (%) 70.00% 70.00% 70.00%
3 Equity (%) 30.00% 30.00% 30.00%
4 Normative Loan 3.99 10.14 10.14
5 Normative Equity 1.71 4.34 4.34

Table 24: GFA addition approved by Commission for FY 2019-20 (INR Crore)
Approved in APR Petitioner's Trued-up by
S. No Particulars
Order Submission Commission
1 Opening Gross Fixed Assets 452.36 452.36 452.36
2 Addition During FY 5.70 14.48 14.48
3 Adjustment/Retirement During FY 0.00 0.00 0.10
4 Closing Gross Fixed Assets 458.06 466.84 466.84

Table 25: Normative Loan addition for FY 2019-20 (INR Crore)


Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Opening Normative Loan 26.11 26.11 26.11
Add: Normative Loan During the
2 3.99 10.13 10.14
year
Less: Normative Repayment
3 15.76 10.82 16.14
equivalent to Depreciation
4 Closing Normative Loan 14.34 25.42 20.11

Table 26: Normative Equity addition for FY 2019-20 (INR Crore)


Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Opening Equity 100.08 135.71 100.08
Additions on account of new
2 1.71 4.34 4.34
capitalization
3 Closing Equity 101.79 140.05 104.42

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 50
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Depreciation
Petitioner’s Submission

The Petitioner has submitted that for computation of depreciation, the opening GFA as per the annual accounts
for FY 2019-20 have been considered at INR 452.36 Crore. Further, the Petitioner has submitted that the
depreciation for the year has been worked out after applying the Depreciation rates as per the JERC (Multi Year
Tariff) Regulations, 2018.

Commission’s Analysis

Regulation 30 of the JERC MYT Regulations 2018, states the following:

“30. Depreciation

30.1 The value base for the purpose of depreciation shall be the capital cost of the asset admitted by the
Commission:

Provided that the depreciation shall be allowed after reducing the approved original cost of the retired or
replaced or decapitalized assets:

Provided also that the no depreciation shall be allowed on the assets financed through consumer
contribution, deposit work, capital subsidy or grant.

30.2 The salvage value of the asset shall be considered as 10% and depreciation shall be allowed up to a
maximum of 90% of the capital cost of the asset

30.3 Land other than the land held under lease shall not be a depreciable asset and its cost shall be excluded
from the capital cost while computing depreciable value of the assets.

30.4 In case of existing assets, the balance depreciable value as on April 1, 2019, shall be worked out by
deducting the cumulative depreciation as admitted by the Commission up to March 31, 2018, from the gross
depreciable value of the assets.

30.5 The depreciation shall be chargeable from the first Year of commercial operations. In case of projected
commercial operation of the assets during the Year, depreciation shall be computed based on the average of
opening and closing value of assets:

Provided that depreciation shall be re-calculated during truing-up for assets capitalised at the time of truing
up of each Year of the Control Period, based on documentary evidence of asset capitalised by the Applicant,
subject to the prudence check of the Commission.
…”

As per the norms specified in the JERC MYT Regulations, 2018, the Commission has verified the asset wise
capitalization of the Petitioner and has accordingly derived the weighted average rate of depreciation based on
the asset wise depreciation rate prescribed in the JERC MYT Tariff Regulations, 2018, provided in the table
below:

Table 27: Depreciation Rate (%)


Description Rate
Plant & Machinery 3.60%
Underground cables 2.57%
Buildings 1.80%
Vehicles 18.00%
Furniture & Fixtures 6.00%
Computers & Others 6.00%
Land 0.00%
Software-Intangible assets 15.00%

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 51
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Based on the above deprecation rates specified in the JERC MYT Tariff Regulations, 2018 and the actual asset
addition during the year, the weighted average deprecation rate is 3.51% against a rate of 3.46% approved in the
APR Order. The Commission has calculated the deprecation on average Gross Fixed Assets (GFA) considering
the opening and closing values approved in Section 3.12 of this Order. The net addition during the year has
been calculated after deducting the value of retired assets. The following table provides the calculation of
depreciation during the year FY 2019-20:

Table 28: Depreciation approved by Commission for FY 2019-20 (INR Crore)


Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Opening Gross Fixed 452.36 452.36 452.36
2 Addition During FY 5.70 14.48 14.58
3 Adjustment/Retirement During FY - - -0.10
4 Closing Gross Fixed Assets 458.06 466.84 466.84
5 Average Gross Fixed Assets 455.21 459.60 459.60
6 Rate of Depreciation (%) 3.46% 2.35% 3.51%
7 Depreciation 15.75 10.82 16.14

The petitioner while calculating the Depreciation used incorrect opening GFA of various assets groups such as
Plant & Machinery & Computers & Others. This has resulted in less estimation of depreciation by the petitioner
as shown in the above table. Hence the significant difference is observed in the depreciation as claimed by the
petitioner & as approved by the Commission for FY 2019-20.

The Commission approves depreciation of INR 16.14 Crore in the true-up of FY 2019-20.

Interest on Loan
Petitioner’s submission

The Petitioner has submitted the Interest on Loan on normative basis. The normative loan addition in FY
2019-20 has been computed as 70% of the capitalization for FY 2019-20. The repayment of loans has been
considered equal to the depreciation during FY 2019-20.

Further, the rate of interest has been considered as the State Bank of India Prime Lending Rate (SBI PLR) as on
April 1, 2019 plus 100 bp, i.e., 9.55%.

Commission’s Analysis

In this regard, Regulation 28 of the JERC MYT Regulations provides:

“28. Interest on Loan

28.1 The loans arrived at in the manner indicated in Regulation 26 on the assets put to use, shall be
considered as gross normative loan for calculation of interest on the loan:

Provided that interest and finance charges on capital works in progress shall be excluded:

Provided further that in case of De-capitalisation or retirement or replacement of assets, the loan capital
shall be reduced to the extent of outstanding loan component of the original cost of the de-capitalised or
retired or replaced assets, based on documentary evidence.

28.2 The normative loan outstanding as on April 1, 2019, shall be worked out by deducting the cumulative
repayment as admitted by the Commission up to March 31, 2018, from the gross normative loan.

28.3 Notwithstanding any moratorium period availed by the Transmission Licensee or the Distribution
Licensee, as the case may be, the repayment of loan shall be considered from the first Year of commercial

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 52
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

operation of the project and shall be equal to the annual depreciation allowed in accordance with Regulation
30.

28,4 The rate of interest shall be the weighted average rate of interest calculated on the basis of the actual
loan portfolio at the beginning of each Year applicable to the Transmission Licensee or the Distribution
Licensee:

Provided that at the time of truing up, the weighted average rate of interest calculated on the basis of the
actual loan portfolio during the Year applicable to the Transmission Licensee or the Distribution Licensee
shall be considered as the rate of interest:

Provided also that if there is no actual loan for a particular Year but normative loan is still outstanding, the
last available weighted average rate of interest for the actual loan shall be considered:

Provided further that if the Transmission Licensee or the Distribution Licensee does not have actual loan,
then one (1) Year State Bank of India (SBI) MCLR / any replacement thereof as notified by RBI for the time
being

in effect applicable for one (1)Year period, as may be applicable as on 1st April of the relevant Year plus 100
basis points shall be considered as the rate of interest for the purpose of allowing the interest on the
normative loan.

28.5 The interest on loan shall be calculated on the normative average loan of the Year by applying the
weighted average rate of interest:

Provided that at the time of truing up, the normative average loan of the Year shall be considered on the
basis of the actual asset capitalisation approved by the Commission for the Year.

28.6 For new loans proposed for each Financial Year of the Control Period, interest rate shall be considered
as lower of (i) one (1) Year State Bank of India (SBI) MCLR / any replacement thereof as notified by RBI for
the time being in effect applicable for one (1) Year period, as may be applicable as on 1st April of the relevant
Year plus 100 basis points, and (ii) weighted average rate of interest proposed by the Distribution Licensee.”

As per the above Regulation, the rate of interest to be considered while determining the ARR shall be the
weighted average interest rate of the actual loan portfolio. However, the Petitioner has submitted that the
complete capitalization during the year has been funded by the equity and no loan has been taken against any of
the capitalized assets. Accordingly, the Commission for the purpose of calculation of Interest on Loan has
considered the interest rate equivalent to SBI MCLR as on April 1, 2019 (8.55%) plus 100 basis points.

Further, in accordance with the JERC MYT Regulations 2018, the interest has been calculated on the average
normative loan during the year with the opening and closing values for loan as approved in Section 3.12 of this
Order. The repayment has been considered equal to depreciation allowed for FY 2019-20.

The following table provides the Interest on Loan approved by the Commission in the APR Order, Petitioner’s
submission and now trued-up by the Commission.

Table 29: Interest on Loan approved by Commission for FY 2019-20 (INR Crore)
Approved in Petitioner's Trued-up by
S. No Particulars
APR Order Submission Commission
1 Opening Normative Loan 26.11 26.11 26.11
2 Add: Normative Loan During the year 3.99 10.14 10.14
Less: Normative Repayment =
3 15.76 10.82 16.14
Depreciation
4 Closing Normative Loan 14.34 25.42 20.11
5 Average Normative Loan 20.22 25.77 23.11
6 Rate of Interest (%) 9.55% 9.55% 9.55%
Interest on Loan 1.93 2.46 2.21

The Commission approves the Interest of Loan of INR 2.21 Crore in the true-up of FY 2019-20.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 53
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Return on Equity (RoE)


Petitioner’s submission

The RoE is calculated in accordance with the JERC MYT Regulations 2018 and is computed on 30% of the
capital base. The equity addition has been considered to the tune of 30% of assets capitalized during the year.
The Petitioner has segregated the approved average equity (average of opening and closing equity) into average
equity for Distribution Wires Business and Retail Supply Business based on the Allocation Statement provided
in the MYT Regulations, 2018 i.e. 90% allocation for the Distribution Wires Business and 10% allocation for the
Retail Supply Business. Petitioner further submitted that the Commission has considered a rate of 15.50% for
the Distribution Wires Business (as per the prevalent CERC Regulations) and a rate of 16% for the Retail Supply
Business. The equity component has been determined in accordance with the Regulation 26 of the MYT
Regulations, 2018.

Commission’s Analysis

Regulation 27.2 and 27.3 of the JERC MYT Regulations, 2018 specifies the following:

“27. Return on Equity

…….

27.2 The return on equity for the Distribution Wires Business shall be allowed on the equity capital
determined in accordance with Regulation 26 for the assets put to use at post-tax rate of return on equity
specified in the prevalent CERC Tariff Regulations for transmission system.

27.3 The return on equity for the Retail Supply Business shall be allowed on the equity capital determined in
accordance with Regulation 26 for the assets put to use, at the rate of sixteen (16) per cent per annum.

………”

Further, in this regard, the Regulation 30(2) of the CERC (Terms and Conditions of Tariff) Regulations, 2019
stipulates the following:

“30. Return on Equity:

………

30.2 Return on equity shall be computed at the base rate of 15.50% for thermal generating station,
transmission system including communication system and run-of river hydro generating station, and at
the base rate of 16.50% for the storage type hydro generating stations including pumped storage hydro
generating stations and run-of river generating station with pondage:
……..” (Emphasis supplied)

The Commission has segregated the approved average equity (average of opening and closing equity) into
average equity for Distribution Wires Business and Retail Supply Business based on the Allocation Statement
provided in the JERC MYT Regulations, 2018, i.e., 90% allocation for the Distribution Wires Business and 10%
allocation for the Retail Supply Business. The Commission has considered a rate of 15.50% for the Distribution
Wires Business (as per the prevalent CERC Regulations mentioned above) and a rate of 16% for the Retail
Supply Business.

The RoE has been calculated on the average of opening and closing of equity during the year at the rate of 16%
on post-tax basis for Retail Supply Business and 15.50% on post-tax basis for wires business, with the opening
equity considered equivalent to the closing equity of FY 2018-19 approved in the True-up of the same. The

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 54
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

following table provides the Return on Equity approved by the Commission in the APR Order, Petitioner’s
submission and now trued-up by the Commission.

Table 30: Return on Equity approved by Commission for FY 2019-20 (INR Crore)
S. Approved in Petitioner’s Now Approved
Particulars
No ARR order Submission by Commission
1 Opening Equity 100.08 135.71 100.08
Additions on account of new
2 1.71 4.34 4.34
capitalization
3 Closing Equity 101.79 140.05 104.42
4 Average Equity 100.94 137.88 102.25
5 Avg. Equity for wire business (90%) 90.84 124.09 92.03
Avg. Equity for Retail Supply Business
6 10.09 13.79 10.23
(10%)
7 Return on Equity for Wire Business (%) 15.50% 15.50% 15.50%
Return on Equity for Retail Supply
8 16.00% 16.00% 16.00%
Business (%)
9 Return on Equity for Wire Business 14.08 19.23 14.26
Return on Equity for Retail Supply
10 1.61 2.21 1.64
Business
11 Return on Equity 15.70 21.44 15.90
The petitioner while calculating Return on Equity considered average equity of FY 2018-19 instead of
considering closing equity of FY 2018-19 as opening equity of FY 2019-20. This resulted in higher estimation of
average equity by the petitioner for FY 2019-20. Hence for FY 2019-20 there is a significant difference in the
return on equity claimed by the petitioner and approved by the Commission.

The Commission approves a Return on Equity of INR 15.90 Crore in the true-up of FY 2019-20.

Additional ROE for FY 2016-17, FY 2017-18 and FY 2018-19


Petitioner’s Submission

The Petitioner submitted that Regulation 27 of MYT Regulations, 2014 provide as follows:

“27. Return on equity

a) The Return on equity shall be computed on 30% of the capital base or actual equity, whichever is
lower:

Provided that assets funded by consumer contribution, capital subsidies/grants and corresponding
depreciation shall not form part of the capital base. Actual equity infused in the Distribution Licensee
as per book value shall be considered as perpetual and shall be used for computation in this
Regulation.

b) The return on the equity invested in working capital shall be allowed from the date of start of
commercial operation.

c) 16% post-tax return on equity shall be considered irrespective of whether the Distribution Licensee
has claimed return on equity in the ARR Petition

As given above, the MYT Regulations, 2014, allow the utility to claim ROE on 30% of the capital base or the
actual equity whichever is lower. However, in the true up order of FY 2016-17, FY 2017-18 & FY 2018-19 the
Commission had allowed ROE on the basis of paid up equity share capital whereas the Regulations specifically
provides that ROE should be allowed on the basis of equity and not on the basis of paid up equity capital. The

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 55
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Petitioner further submitted that Regulation specifically states that ROE should be allowed irrespective of
whether the Distribution Licensee has claimed return on equity in the ARR Petition.

Accordingly, the Petitioner has claimed a total of INR 17.11 Cr as additional ROE for FY 2016-17 FY 2017-18 &
FY 2018-19 (INR 5.70 Crore for FY 2018-19 and INR 11.41 Crore for FY 2016-17 & FY 2017-18).

Commission’s Analysis

The Petitioner had also raised the same issue of variation in Opening Equity for FY 2017-18 in the Review
Petition filed on the Commission’s Order dated May 20, 2019. In this regard, the Commission in its Order dated
September 24, 2019, on the Review Petition ruled as follows:

“The Review Petitioner’s contention is about difference in equity base upon which return on equity is allowed.
The opening level of equity base for FY 2017-18 is the same as approved closing value of equity for FY 2016-17.
The Review Petitioner did not file any Review Petition on the True-up Order for FY 2016-17 regarding the
closing equity value of FY 2016-17. There is no merit in changing the opening value of equity for FY 2017-19 as
per 30% of opening value of GFA. The Commission has considered the equity addition @30% for the approved
capitalization for FY 2017-18 which is in line with the extant MYT Regulations.

As can be seen above, due to the Review Petitioner’s inability to submit the project wise equity infusion details,
the Commission was forced to consider opening equity value for FY 2017-18 equal to approved closing value
of equity for FY 2016-17 as the part of methodology followed. The Commission is of the opinion that this issue
does not warrant a review as there is no error in impugned order.”

The Commission in the true up orders of FY 2016-17, FY 2017-18 & FY 2018-19 had allowed Return on equity
on the basis of paid up equity share capital instead of entire equity.

Accordingly, in line with the approach followed by the Commission in true up of FY 2016-17, FY
2017-18 & FY 2018-19 the Commission has not considered the Petitioner’s submission to allow
additional Return on equity.

Interest on Security Deposits


Petitioner’s Submission

Payments of INR 4.20 Crore were released to the consumers towards interest on security deposits during FY
2019-20 against INR 2.70 Crore which was approved by the Commission in the APR Order.

Commission’s Analysis

As per Regulation 5.135 of the JERC Electricity Supply Code Regulations, 2018-

“5.135 The Licensee shall pay interest to the consumer at the State Bank of India Base Rate prevailing on the
1st of April for the year, payable annually on the consumer’s security deposit with effect from date of such
deposit in case of new connections energized after the date of this notification, or in other cases, from the
date of notification of this Supply Code, 2018. The interest accrued during the year shall be adjusted in the
consumer’s bill for the first billing cycle of the ensuing financial year. If the Security Deposit is submitted in
the form of Bank Guarantee or by providing lien against fixed deposits, no interest shall be payable to the
consumer.”

Accordingly, the Commission has considered the actual interest on security deposit disbursed to the consumers
in their bills, as reflected in the audited accounts of FY 2019-20 for truing-up.

The interest on consumer’s Security Deposits approved by the Commission in APR Order, Petitioner’s
submission and now Trued- up by the Commission are shown in the following Table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 56
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Table 31: Interest on security deposit approved by Commission for FY 2019-20 (INR Crore)
Approved in APR Petitioner’s Trued-up by
S. No Particulars
Order Submission Commission
1 Interest on Security Deposit 2.70 4.20 4.20

The Commission approves Interest on Security Deposit of INR 4.20 Crore in the true-up of FY
2019-20.

Interest on Working Capital


Petitioner’s Submission

The interest on working capital has been calculated based on the normative principles outlined by the
Commission in the JERC (Multi Year Tariff) Regulations, 2018.

The working capital requirement for the Control Period has been computed considering the following
parameters:

a. O&M expense for one month


b. Maintenance spares at 40% of R&M for one month
c. Receivables for 2 months
d. Less consumer security deposit but excluding Bank Guarantee/Fixed Deposit Receipt

DNHPDCL has computed interest on working capital at 10.55% (SBI base rate as on 1st April, 2019 plus 200
basis points) as has been shown in the table below:

Table 32: Interest on Working Capital submitted by Petitioner for FY 2019-20 (INR Crore)
Approved in ARR Petitioner's
S. No Particulars
Order Submission
1 O&M expense for one month 2.52 3.31
Maintenance spares at 40% of R&M for one
2 0.38 0.65
month
3 Receivables for 2 months 562.82 561.64
4 Total 565.72 565.60
Less consumer security deposit but excluding
5 53.08 60.63
Bank Guarantee/Fixed Deposit Receipt
Net Working Capital required after deduction of
6 512.64 504.97
Security Deposit
7 Interest on Working Capital 54.08 53.27

Commission’s Analysis

The computation of working capital requirements and the rate of interest to be considered are stipulated in the
JERC MYT Regulations, 2018. Regulation 52.1 & 31 of the JERC MYT Regulations 2018 states the following:

“52.1 The Distribution Licensee shall be allowed interest on the estimated level of working capital for the
Distribution Wires Business for the Financial Year, computed as follows:

(a) O&M Expense for 1 month; plus


(b) Maintenance spares at 40% of R&M expenses for one (1) month; plus
(c) Receivables equivalent to two (2) months of the expected revenue from charges for use of distribution
wires at the prevailing tariff;
Less
(d) Amount, held as security deposits

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 57
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

………

31.4 The rate of interest on working capital shall be equal one (1) Year State Bank of India (SBI) MCLR / any
replacement thereof as notified by RBI for the time being in effect applicable for one (1)Year period, as may
be applicable as on 1stApril of the Financial Year in which the Petition is filed plus 200 basis points.”

As above, the Commission for determination of working capital requirements of the Petitioner during the year,
has considered the receivables equivalent to two months of the expected revenue requirement, the consumer
security deposit, the O&M Expenses for one month & Maintenance spares as 40% of R&M expenses as per the
audited accounts of FY 2019-20.

With regards to the interest rate, the Commission has considered the SBI MCLR rates (One Year) as on April 1,
2019 plus 200 basis points which is 10.55%.

The following table provides the interest on working capital approved by the Commission in the APR Order,
Petitioner’s submission and now trued-up by the Commission.

Table 33: Interest on Working Capital approved by Commission for FY 2019-20 (INR Crore)
Approved in Petitioner’s Trued-up by
S. No. Particulars
APR Order Submission Commission
1 Receivables of two months of billing 2.52 3.31 2.41
Less: Power Purchase Cost for one
2 0.38 0.65 0.31
month
Inventory Based on Annual
3 Requirement for Previous FY for 2 562.82 561.64 561.64
months
4 Total Working Capital Requirement 565.72 565.60 564.36
Less: Security Deposit excluding
5 53.08 60.63 60.63
BG/FDR
6 Net Working Capital 512.64 504.97 503.73
7 Rate of Interest (%) 10.55% 10.55% 10.55%
Interest on Working Capital 54.08 53.27 53.14

The Commission approves the Interest on Working Capital of INR 53.14 Crore in the true-up of
FY 2019-20.

Income Tax
Petitioner’s submission

The Petitioner submitted Income tax liability for FY 2019-20 as INR 2.63 Cr.

Commission’s Analysis:

In this regard, Regulation 32 of the JERC MYT Regulations, 2018, states the following:

“32. Tax on Income

32.1 The treatment of tax on income for a Transmission Licensee shall be in accordance with the prevalent
CERC Tariff Regulations.

32.2 The Commission in its MYT Order shall provisionally approve Income Tax payable for each Year of the
Control Period, if any, based on the actual income tax paid, including cess and surcharge on the same, if any,
as per latest audited accounts available for the Distribution Licensee, subject to prudence check.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 58
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

32.3 Variation between Income Tax actually paid, including cess and surcharge on the same, if any, and
approved, if any, on the income stream of the Licensed business of the Distribution Licensees shall be
reimbursed to/recovered from the Distribution Licensees, based on the documentary evidence submitted at
the time of truing up of each Year of the Control Period, subject to prudence check.

32.4 Under-recovery or over-recovery of any amount from the Consumers on account of such tax having been
passed on to them shall be adjusted every Year on the basis of income-tax assessment under the Income-Tax
Act, 1961, as certified by the statutory auditors. The Distribution Licensee may include this variation in its
truing up Petition:

Provided that tax on any income stream other than the core business shall not be a pass-through component
in tariff and tax on such other income shall be borne by the Distribution Licensee.”

Further, the Regulation 64 of the JERC MYT Regulations, 2018 stipulates the following:

“64. Non-Tariff Income

64.1 The amount of Non-Tariff Income relating to the retail supply of electricity as approved by the
Commission shall be deducted from the Aggregate Revenue Requirement in calculating the tariff for retail
supply of electricity by the Distribution Licensee:

Provided that the Distribution Licensee shall submit full details of its forecast of Non-Tariff Income to the
Commission along with its application for determination of tariff.

64.2 The Non-Tariff Income shall inter-alia include:

(a) Income from rent of land or buildings;


(b) Income from sale of scrap;
(c) Income from statutory investments;
(d) Interest on advances to suppliers/contractors;
(e) Rental from staff quarters;
(f) Rental from contractors;
(g) Income from hire charges from contactors and others;
(h) Income from advertisements, etc.;
(i) Meter/metering equipment/service line rentals;
(j) Service charges;
(k) Consumer charges;
(l) Recovery for theft and pilferage of energy;
(m) Rebate availed on account of timely payment of bills;
(n) Miscellaneous receipts;
(o) Deferred Income from grant, subsidy, etc., as per Annual Accounts;
(p) Prior period income, etc.:

Provided that the interest/dividend earned from investments made out of Return on Equity
corresponding to the Retail Supply Business of the Distribution Licensee shall not be included
in Non-Tariff Income:

…….” (Emphasis supplied)

Further, the Regulation 34.2 of the JERC MYT Regulations, 2018 stipulates the following:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 59
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

“34.2 The delayed payment charge earned by the Transmission Licensee or the Distribution Licensee shall not
be considered under its Non-Tariff Income.”

The Petitioner has claimed INR 2.63 Cr as the income tax paid. The income tax paid was verified by the
payment receipts provided by the petitioner and also from the audited annual accounts for FY 2019-20. The
Commission has observed that the actual tax payment is as per the latest audited accounts available (Note 36
P&L Accounts) for FY 2019-20.

But the Commission has observed that the Petitioner has paid the income tax on total income comprising of
income from sale of power & other income like interest income, delayed payment charge, etc. As per the above
Regulations, since interest income & income by delayed payment charges are not to be considered as non-tariff
income, the income tax on interest income and income from delayed payment charges is proportionately
reduced from total income tax while allowing the income tax in ARR, which has been shown in the following
table:

Table 34: Income Tax approved by Commission for FY 2019-20 (INR Crore)
Approved in APR Petitioner’s Trued-up by
S. No Particulars
Order Submission Commission
1 Income Tax 0.00 2.63 2.60

The Commission approves Income Tax liability as INR 2.60 Cr for FY 2019-20.

Provision for Bad & Doubtful Debts


Petitioner’s submission

The Petitioner has not claimed any amount towards provision for bad and doubtful debts for FY 2019-20.

Commission’s Analysis

As per Regulation 62.1 of the MYT Regulations, 2018:

“62.1 Bad and Doubtful Debts shall be limited to 1% of receivables in the True-up, subject to the condition that
amount of bad and doubtful debts have actually been written off in the licensee books of accounts.”

The Commission may allow bad debts written off as a pass through in the Aggregate Revenue Requirement,
based on the trend of write off of bad debts in the previous years, subject to prudence check:

Provided that the Commission shall true up the bad debts written off in the Aggregate Revenue Requirement,
based on the actual write off of bad debts excluding delayed payment charges waived off, if any, during the
year, subject to prudence check:

Provided also that the provision for bad and doubtful debts shall be limited to 1% of the annual Revenue
Requirement of the Distribution Licensee:

Provided further that if subsequent to the write off of a particular bad debt, revenue is realised from such bad
debt, the same shall be included as an uncontrollable item under the Non-Tariff Income of the year in which
such revenue is realised.”

As the Petitioner has not claimed any amount towards Bad Debts, the Commission therefore
has not considered any bad and doubtful debts in the true-up of FY 2019-20.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 60
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Non-Tariff Income (NTI)


Petitioner’s Submission

The Petitioner has submitted the actual Non-Tariff Income of INR 8.22 Crore for FY 2019-20.

Commission’s Analysis

The Regulation 64 of the JERC MYT Regulations, 2018 stipulates the following:
“64. Non-Tariff Income

64.1 The amount of Non-Tariff Income relating to the retail supply of electricity as approved by the
Commission shall be deducted from the Aggregate Revenue Requirement in calculating the tariff for retail
supply of electricity by the Distribution Licensee:

Provided that the Distribution Licensee shall submit full details of its forecast of Non-Tariff Income to the
Commission along with its application for determination of tariff.

64.2 The Non-Tariff Income shall inter-alia include:

(a) Income from rent of land or buildings;


(b) Income from sale of scrap;
(c) Income from statutory investments;
(d) Interest on advances to suppliers/contractors;
(e) Rental from staff quarters;
(f) Rental from contractors;
(g) Income from hire charges from contactors and others;
(h) Income from advertisements, etc.;
(i) Meter/metering equipment/service line rentals;
(j) Service charges;
(k) Consumer charges;
(l) Recovery for theft and pilferage of energy;
(m) Rebate availed on account of timely payment of bills;
(n) Miscellaneous receipts;
(o) Deferred Income from grant, subsidy, etc., as per Annual Accounts;
(p) Prior period income, etc.:

Provided that the interest/dividend earned from investments made out of Return on Equity corresponding to
the Retail Supply Business of the Distribution Licensee shall not be included in Non-Tariff Income:

Provided further that any income earned by a Distribution Licensee by sale of power to other Distribution
Licensees or to Consumers as per Section 49 of the Act using the existing power purchase agreements or bulk
supply capacity allocated to the Distribution Licensee’s Area of Supply shall be reduced from the Aggregate
Revenue Requirement of the Distribution Licensee for the purpose of determination of tariff. Such reduction
shall be carried out in accordance with Joint Electricity Regulatory Commission for the State of Goa and
Union Territories (Connectivity and Open Access in Intra-State Transmission and Distribution) Regulations,
2017, as amended from time to time.”

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 61
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

In accordance with the above, Delayed Payment Surcharge & Interest on FD & others are not to be considered
as Non-Tariff Income (NTI). The NTI claimed by Petitioner and now trued-up by the Commission is shown in
the following table:

Table 35: Non-Tariff Income Approved by Commission for FY 2019-20 (INR Crore)
S. No. Particulars Petitioner's Submission Trued-up by Commission
1 Delayed Payment Charges - 0.00
2 Reactive Charges Receivables - 0.03
3 Capacitor Charges - -
4 Interest on FD and Others - 0.00
5 Meter Testing Charges - 0.08
6 Other Charges (Indirect) - -
7 Reconnection Charges - 0.02
8 Registration Fees - 2.00
9 Service Connection Charges - 0.34
10 Supervision Charges - 2.08
11 Tender Fees 0.02 0.02
12 Penalty Charges - -
13 STOA Application Receivables - 0.97
14 Recovery of doubtful debt - -
15 Others - -
16 Provision for written back 0.09 0.09
17 sale of scrap 0.23 0.23
18 Test report charges - 0.05
19 Assessment Charges from
- 2.26
consumers
20 Licensee Fees - 0.00
21 Operating Income 5.57 -
22 Other Miscellaneous Income 2.30 3.30
23 Gross Total 8.22 11.48

The Commission further observed that the petitioner did not include revenue from some of the sources in Non-
tariff income as provided in annual accounts of FY 2019-20, as shown in the above Table. For instance, the
revenue from sources like Assessment charges from consumers, supervision charges, registration fees, etc. are
not considered by the Petitioner. But the Commission has included revenue from all the appropriate sources in
Non-Tariff income as per Regulation 64 of the JERC MYT Regulations, 2018. Hence the significant variation is
observed in petitioner proposed and Commission approved Non-tariff income for FY 2019-20.

Accordingly, the Commission approves Non-Tariff Income of INR 11.48 Crore in the true-up of
FY 2019-20.

Incentive/Disincentive towards over/under achievement of


norms of distribution losses
Petitioner’s Submission:

The Incentive towards over achievement of norms of distribution losses has been considered INR 15.18 Cr by
the Petitioner and added to ARR.

Commission’s Analysis

In the APR for FY 2019-20, the Commission had approved the T&D loss level of 4.30%. The Petitioner has
achieved T&D loss of 3.47% against the approved loss level of 4.30%. The Commission, in accordance with
Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 62
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

Regulation 14.1 of the JERC MYT Regulations, 2018 (reproduced below) has determined the incentive towards
the over-achievement of the target of distribution loss for FY 2019-20 as follows:

“14.1 Approved aggregate gain to the Transmission Licensee or Distribution Licensee on account of
controllable Factor shall be shared equally between Licensee and Consumers:
………”

The incentive has been considered at INR 5.11/kWh, which is the Average Power Purchase cost (APPC) of the
Petitioner for FY 2019-20. The APPC has been derived at State/UT Periphery based on the Power Purchase
cost less cost of renewable energy certificates to meet RPO approved in the true-up and the Energy at the
State/UT Periphery has been computed after grossing up the retail energy sales (6,513.85 MU) with the actual
Intra-State T&D Loss (3.47%).

Further the JERC MYT Regulations, 2018, stipulate the variation in distribution losses to be a controllable
factor and any approved gain to the Distribution Licensee on account of controllable factors shall be shared
equally between Licensee and Consumers.

The assessment of incentive for lower T&D losses and O&M Expenses is as shown in the following table:

Table 36: Incentive due to over-achievement of Distribution Loss target for FY 2019-20 (INR Crore)
Trued-up by
S. No Particulars Approved in APR
Commission
1 Retail Sales (MU) 6288.00 6288.00
2 T&D Loss (%) 4.30% 3.47%
3 Power at State/UT Periphery (MU) 6570.53 6513.85
4 Gain/ (Loss) (MU) 56.68
5 Average Power Purchase Cost (INR/kWh) 5.11
6 Gain/ (Loss) (INR Crore) 28.94
Sharing of Gain / (Loss) with 14.47
7
Petitioner (INR Crore)

The Commission approves INR 14.47 Crore as incentive for over-achieving the distribution loss
target for FY 2019-20.

Aggregate Revenue Requirement (ARR)


Petitioner’s submission

Based on the expenses as detailed above, the Petitioner has submitted the net Aggregate Revenue Requirement
of INR 3,646.81 Crore for approval in the True-up of FY 2019-20.

Commission’s Analysis

The Commission on the basis of the detailed analysis of the cost parameters of the Aggregate Revenue
Requirement approves the net revenue requirement in the true-up of FY 2019-20 as given in the following
table:

Table 37: Aggregate Revenue Requirement approved by Commission for FY 2019-20 (INR Crore)
S. Approved in Petitioner's Trued-up by
Particulars
No APR Order Submission Commission
1 Power Purchase Cost 3,495.69 3,488.16 3,488.15
2 Operation & Maintenance Expenses 30.30 39.76 28.96
3 Depreciation 15.76 10.82 16.14
4 Interest and Finance charges 1.93 2.46 2.21
5 Return on Equity 15.70 21.44 15.90

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 63
DNH Power Distribution Corporation Limited (DNHPDCL)
True- Up for FY 2019-20 Joint Electricity Regulatory Commission (JERC)

S. Approved in Petitioner's Trued-up by


Particulars
No APR Order Submission Commission
6 Additional ROE 0.00 17.11 0.00
7 Interest on Security Deposit 2.70 4.20 4.20
8 Interest on Working Capital 54.08 53.27 53.14
9 Income Tax 0.00 2.63 2.60
10 Provision for Bad Debt 0.00 0.00 0.00
Incentive/ (Disincentive)on
11 0.00 15.18 14.47
achievement of norms
13 Total Revenue Requirement 3,616.15 3,655.03 3,625.76
14 Less: Non-Tariff Income 14.17 8.22 11.48
15 Net Revenue Requirement 3,601.97 3,646.81 3,614.28
The Commission approves net Aggregate Revenue Requirement of INR 3,614.28 Crore in the
true-up of FY 2019-20.

Revenue at existing Retail Tariff


Petitioner’s submission

The actual revenue from retail sale for FY 2019-20 is INR 3,369.82 Crore as against INR 3,376.89 Crore
approved by the Commission in the APR Order.

Commission’s Analysis
The Petitioner submitted INR 3,369.82 Crore as revenue from sale of power. The Commission analyzed the
sales and revenue figures for each consumer category and checked the revenue from audited accounts of FY
2019-20. The Revenue from sale of power as provided in the annual accounts is INR 3,371.08 Crore, out of
which INR 1.26 Crore was provided as rebate to consumers. Hence, the net revenue from sale of power is INR
3,369.82 Crore.
The Commission approves the revenue from sale of power as INR 3,369.82 Crore in the true-up
of FY 2019-20.

Standalone Revenue Gap/ Surplus


Petitioner’s submission
Based on the ARR and the revenue from retail tariff, the standalone revenue gap of INR 276.99 Crore is arrived
in the true-up of FY 2019-20.
Commission’s Analysis
The Commission based on the approved ARR and retail tariff has arrived at the Revenue Gap/(Surplus) as
follows:

Table 38: Standalone Revenue Gap/ (Surplus) for FY 2019-20 (INR Crore)
S. Approved in Petitioner's Trued-up by
Particulars
No APR Order Submission Commission
1 Net Revenue Requirement 3,601.97 3,646.81 3,614.28
2 Revenue from Retail Sales at Existing Tariff 3,376.90 3,369.82 3,369.82
3 Revenue from Open Access Charges 0.00 0.00 0.00
4 Total Revenue 3,376.90 3,369.82 3,369.82
5 Net Standalone Gap / (Surplus) 225.08 276.99 244.46
The Commission, in the true-up of FY 2019-20 approves a standalone gap of INR 244.46 Crore.
This standalone gap has been carried over in the subsequent years and has been dealt with
while determining the tariff for FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 64
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

4. Chapter 4: Annual Performance


Review for FY 2020-21

Background
The Tariff Order for approval of true-up of FY 2018-19, Annual Performance Review of FY 2019-20 and
Aggregate Revenue Requirements (ARR) for FY 2020-21 and determination of tariff for FY 2020-21 was issued
by the Commission on May 18, 2020 (hereinafter referred to as ‘ARR Order’ for the purpose of APR of FY 2020-
21). This Chapter covers the Annual Performance Review (APR) for FY 2020-21 vis-à-vis the cost parameters
approved by the Commission in the ARR Order. The Annual Performance Review for FY 2020-21 is to be
carried out as per the following provisions of Regulation 11 of the JERC (Multi Year Tariff) Regulations, 2018:

““11. Annual Performance Review, Truing-up and tariff determination during the Control
Period

11.1 The Generating Company, Transmission Licensee and Distribution Licensee shall be subject to annual
performance review and truing up of expenses and revenue during the Control Period in accordance with
these Regulations

11.2 The Generating Company, Transmission Licensee and Distribution Licensee shall file an application for
the annual performance review of the current year, truing up of the previous Year or the Year for which the
audited accounts are available and determination of tariff for the ensuing Year on or before 30th November
of each Year, in formats specified by the Commission from time to time:

Provided that the Generating Company, Transmission Licensee or Distribution Licensee, as the case may be,
shall submit to the Commission information in such form as may be specified by the Commission, together
with the audited accounts, 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.

11.3 The scope of the annual performance review, truing up and tariff determination shall be a comparison of
the performance of the Generating Company, Transmission Licensee or Distribution Licensee with the
approved forecast of Aggregate Revenue Requirement and Expected Revenue from Tariff and Charges and
shall comprise of the following:

…..

b) Annual Performance Review: a comparison of the revised performance targets of the Applicant for the
current Financial Year with the approved forecast in the Tariff Order corresponding to the Control Period for
the current Financial Year subject to prudence check;

…..

d) Review of compliance with directives issued by the Commission from time to time;

e) Other relevant details, if any.

11.4 Upon completion of the exercise, the Commission shall attribute any variations or expected variations in
performance for variables specified under Regulation 12below, to factors within the control of the Applicant
(controllable factors) or to factors beyond the control of the Applicant (uncontrollable factors):

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 65
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Provided that any variations or expected variations in performance, for variables other than those specified
under Regulation 12 below shall be attributed entirely to controllable factors.

11.5 Upon completion of the exercise, the Commission shall pass an order recording:

a) Components of approved cost pertaining to the uncontrollable factors, which were not recovered during
the previous Year, to be passed through in tariff as per Regulation 13 of these Regulations:

Provided that, for a Generating Company, the above exercise shall be in accordance with prevalent CERC
Tariff Regulations.

b) Approved aggregate gain or loss to the Transmission Licensee or Distribution Licensee on account of
controllable factors, and the amount of such gains or such losses that may be shared in accordance with
Regulation 14of these Regulations:

Provided that, for a Generating Company, the above exercise shall be in accordance with prevalent CERC
Tariff Regulations.

c) Carrying cost shall be allowed for a Generating Company, Transmission Licensee or Distribution Licensee
on the amount of revenue gap for the period from the date on which such gap has become due, i.e., from the
end of the Year for which true-up has been done, till the end of the Year in which it is addressed, on the basis
of actual rate of loan taken by the Licensee to fund the deficit in revenue:

Provided that carrying cost on the amount of revenue gap shall be allowed subject to prudence check and
submission of documentary evidence for having incurred the carrying cost in the years prior to the year in
which the revenue gap is addressed:

Provided also that if no loan has been taken to fund revenue deficit, the Commission shall allow Carrying Cost
on simple interest basis at one (1) Year State Bank of India (SBI) MCLR /any replacement thereof as notified
by RBI for the time being in effect applicable for 1 Year period, as may be, applicable as on 1st April of the
relevant Year plus 100 basis points;

Provided further that in case of revenue surplus, the Commission shall charge the Licensee a Carrying Cost
from the date on which such surplus has become due, i.e., from the end of the Year for which true up has been
done, till the end of the Year in which it is addressed on simple interest basis at one(1) Year State Bank of
India (SBI) MCLR / any replacement thereof as notified by RBI for the time being in effect applicable for 1
Year period, as may be, applicable as on 1st April of the relevant Year plus 100 basis points.

d) Revision of estimates and tariff for the ensuing Financial Year.”

Approach for the Review for FY 2020-21


The review of the Aggregate Revenue Requirement requires assessment of the quantum of energy sales, energy
loss as well as the various cost elements like Power Purchase Cost, O&M expenses, interest on long term loans,
interest on working capital loans, depreciation etc. The Annual Performance Review for FY 2020-21 has been
done based on actual Power Purchase Quantum and Cost of the first 9 months of FY 2020-21, actual Energy
Sales for the first 9 months, etc., based on which the estimates for the remaining months of the financial year
have been made. The various cost elements constituting the Aggregate Revenue Requirement have been
approved based on the actual information submitted by the Petitioner for 9 first months of FY 2020-21, the
JERC MYT Regulations, 2018 and on the basis of the norms approved in the ARR Order dated May 18, 2020.

In order to mitigate the hardship of Electricity Consumers and DISCOMs/EDs in view of nationwide lockdown
due to COVID-19, the Commission had issued SUO MOTU ORDER NO. JERC/LEGAL/SMP/27/2020 on 10th
April, 2020 wherein the Commission provided relief to industrial and commercial consumers and
acknowledged the need for additional working capital requirement by the Distribution Licensees. Further, the
Commission viewed that the lockdown will also impact certain other parameters of ARR like sales/sales mix,
power purchase quantum and cost and revenue. The Commission opined that it will consider all such additional

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 66
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

costs and variations in parameters appropriately while evaluating the APR of FY 2020-21 and thereafter True-
up of FY 2020-21. Accordingly, the Commission has considered the impact of lower sales, rebate received in
power purchase cost and some other parameters due to COVID 19 as part of APR for FY 2020-21. Further, the
Commission will consider the actual impact of COVID 19 on various parameters of ARR while carrying out the
truing up for FY 2020-21.

Energy Sales
Petitioner’s Submission

The Petitioner in its Petition submitted that the sales for FY 2020-21 have been estimated based on actual sales
by the Corporation during the first six months of FY 2020-21. Total sales of 5153.96 MU have been estimated
against the 6689.48 MU as approved by the Commission in the ARR Order for FY 2020-21.

Commission’s Analysis

The Commission through the deficiency note asked the Petitioner to submit the category-wise actual sales for
first 9 months of FY 2020-21 i.e., from April 2020 to December 2020, in both kWh and kVAh. The Commission
has noted the audited figures for FY 2019-20 and provisional information provided by the Petitioner for the
first 9 months of FY 2020-21. For all the consumers’ categories, the Commission has estimated the proportion
of actual energy sales till the month of December over total energy sales during the financial year, for the last
three years. Using this average proportion of sales, the Commission has extrapolated the actual energy sales till
the month of December for the full year to determine the annual energy sales for FY 2020-21.

However, while applying the method as mentioned in above Para, the Commission has re-calculated the sales
for March 2020. Since the national lockdown was announced on March 22 nd 2020, the sales for remaining part
of the month of March, i.e., from 22.03.2020 to 31.03.2020, were not included in the sales for FY 2019-20. The
Commission decided to project sales for FY 2020-21 considering business as usual scenario in FY 2019-20.
Hence it was necessary to ‘normalize’ the sales for the month of March’ 2020.

The Commission calculated ‘Expected sales for March’ 2020 by escalating the sales of February’ 2020 by a
percentage to arrive at normal sales for March 2020. After escalating for category wise sales the Commission
has considered the higher number between the actual and the escalated number. This percentage is growth
percentage of sales for month of Mar 2019 over sales of Feb 2019. This has resulted in projection of sales for FY
2020-21 in business as usual scenario.

The table below provides the energy sales approved by the Commission in the ARR Order, the Petitioner’s
submission and now approved by the Commission for FY 2020-21.

Table 39: Energy Sales (MU) approved by the Commission for FY 2020-21
Approved in Petitioner’s Now Approved by
S. No. Category
ARR Order Submission Commission
1 Domestic 153.82 154.19 146.07
2 Low Income Group (LIG) 0.00 10.45 0.00
3 Commercial/Non Domestic 39.23 33.78 38.84
4 Agriculture 7.14 5.01 6.21
5 LT Industry 234.21 181.50 186.94
6 Public Lighting 3.09 2.68 3.26
7 Public water works 5.69 5.00 5.18
8 HT/EHT Industry 6,243.48 4,757.71 4,753.10
9 Temp. Supply 2.82 3.62 3.30
Gross Total 6,689.48 5,153.96 5,142.89

The Commission approves energy sales of 5,142.89 MU in the APR of FY 2020-21.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 67
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Inter-State Transmission Loss


Petitioner’s submission

The Petitioner has considered the Inter-State Transmission Loss of 3.66% in FY 2020-21.

Commission’s Analysis

The Commission in the APR of FY 2020-21 considers the Inter-State transmission losses in line with those
approved in the ARR Order. The same shall be revised based on actuals during the true-up exercise of FY 2020-
21.

The following table provides the Inter-State transmission loss submitted and now approved by the Commission.

Table 40: Inter-State Transmission Loss for FY 2020-21 (%)


Approved in Petitioner's Now Approved by
S. No Particulars
ARR Order Submission Commission
1 Inter-State Transmission Losses 3.66% 3.66% 3.66%

The Commission approves Inter-State transmission loss of 3.66% in the APR of FY 2020-21.

Distribution Loss
Petitioner’s submission

The Petitioner has submitted distribution losses of 4.20% for FY 2020-21 same as approved by the Commission
in the ARR Order.

Commission’s Analysis

Regulation 12.2 (c) of the JERC, MYT Regulations, 2018, provides as follows:

“12.2 For the purpose of these Regulations, the term “controllable factors” for a Transmission or Distribution
Licensee shall comprise of the factors which were within the control of the Licensee, shall inter-alia include:

…..

c) Variations in technical and commercial losses of Distribution Licensee;

……….”

As per Regulation 12.2 (c) of the JERC, MYT Regulations, 2018, distribution loss is a controllable factor. The
Commission approves the same loss level as approved in the MYT Order dated May 20, 2019.

Further, in accordance to Regulation 14 of the JERC, MYT Regulations, 2018, mechanism for sharing of gains
or losses on account of controllable factors, the Petitioner shall be allowed an incentive/disincentive in the true-
up Order considering the actual distribution loss achieved by the Petitioner in the year.

The following table provides the Distribution loss approved in the ARR Order, the Petitioner’s submission and
now approved by the Commission.

Table 41: Distribution loss for FY 2020-21 (%)


Approved in Petitioner's Now Approved by
S. No Particulars
ARR Order Submission Commission
1 Distribution Loss 4.20% 4.20% 4.20%

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 68
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

The Commission approves distribution loss of 4.20% in the APR of FY 2020-21.

Energy Balance
Petitioner’s submission

The energy requirement as submitted by the Petitioner for FY 2020-21 has been shown in the following table:

Table 42: Energy Balance as submitted by the Petitioner for FY 2020-21 (MU)
Particulars Value

Sales 5,153.96
Open Access Sales 0.00
Less: Energy Savings 0.00
Total Sales 5153.96
Add: Losses 225.96
T&D Losses (%) 4.20%
Energy Required at Periphery 5379.91
Add: Sales to common pool consumer 0.79
Add: Sales through IEX 67.30
Less: Own Generation 6.18
Total energy requirement at state periphery 5441.82
Less: Energy Purchased through UI at Periphery 11.73
Less: Purchase from Renewable Sources 000
Less: Open Access Purchase 0.00
Less; Power from Power Exchange 646.55
Total Energy Required at Periphery 4783.54
Transmission loss 181.73
Transmission loss (%) 3.66%
Total Energy to be purchased 4965.27
Total Energy requirement from tied up sources & UI at generator end 5629.73
Total Energy requirement in UT including Open Access 5629.73

The Petitioner has estimated the Total Energy requirement from the tied-up sources & UI at generator end as
5,629.73 MU in the APR for FY 2020-21.

Commission’s Analysis

The energy requirement at State/UT Periphery is derived based on the energy sales estimate and the Intra-State
transmission losses and Distribution losses approved for FY 2020-21, as shown in the following Table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 69
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Table 43: Energy Balance as approved by the Commission for FY 2020-21 (MU)
Now
Sr. Approved in Petitioner's
Particulars Formula Approved by
No. ARR Order Submission
Commission
A Energy sales within the State/UT 6,689.48 5,153.96 5142.89
B Open Access Sales 0.00 0.00 0.00
C Less: Energy Savings 0.00 0.00 0.00
Total Sales within the D=A+B+
D 6689.48 5153.96 5142.89
State/UT C
Distribution losses
E in % 4.20% 4.20% 4.20%
F In MU F=G-D 293.28 225.96 225.47
Energy required at State G=D/(1-
G 6982.76 5379.91 5368.37
Periphery E)
Energy Transactions at
Periphery
Add: Sales to common pool
H 0.00 0.79 0.00
consumer
I Add: Sales through IEX 0.00 67.30 0.00
J Less: Own Generation 5.38 6.18 6.18
Less: Energy Purchased through
K 6977.38 5441.82 5362.19
UI at Periphery
Less: Purchase from Renewable
L 1664.40 0.00 28.25
sources
M Less: UI Overdrawl 0.00 11.73 24.13
Less: Purchase from Power
N 0.00 646.55 463.74
Exchanges
Total energy requirement at O=G+H+
O State Periphery from tied-up I-J-K-L- 5312.98 4783.54 4846.06
Sources M-N
Transmission losses
P in % 3.66% 3.66% 3.66%
Q in MU Q=R-O 201.84 181.73 184.10
Total requirement from tied-up R=O/ (1-
R 5514.82 4965.27 5030.16
sources at generator end (MU) P)
Total requirement from
Tied-up sources including
S S=R+N 5514.82 5611.82 5493.90
purchase from Power
Exchange
Total availability from tied
T up sources at generator end 5030.16
(MU)
U Deficit/(surplus) U=S-T 463.74

The Commission approves the Total Energy available at the generator end (from firm sources)
as 5,030.16 MU in the APR for FY 2020-21. The Commission has estimated a deficit of 463.74
MU and has assumed that the deficit power will be purchased from the Open Market. The
Commission has considered a price of INR 2.88/kWh for such power, considering the same as
actual average per unit rate of first nine months of FY 2020-21. This has been included in the
Power Purchase cost allowed by the Commission.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 70
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Power Purchase Quantum & Cost

4.7.1. Availability of power


Petitioner’s submission:

Dadra & Nagar Haveli has no generating stations of its own and relies on the firm and infirm allocation of
power from Central Generating Stations like NTPC Korba, NTPC Vindhyachal, NTPC Kahalgaon, NTPC Kawas,
NTPC Sipat, NPCIL Tarapur, NPCIL Kakrapar, etc., to meet its energy requirement.

The DNHPDCL for the purpose of estimation of the power availability during FY 2020-21 has considered the
following sources of power:

• NTPC Western Region Generating Stations


• NTPC Eastern Region Generating Stations
• NSPCL Bhilai
• Nuclear Power Corporation of India Limited (NPCIL)
• Private Sector Power Generating Companies
• Renewable energy sources – Solar and Non-Solar
• Other market sources

The Petitioner has allocation from Western as well as Eastern region from coal, gas and nuclear power stations.
However, for meeting the supply-demand gap during the peak hours, the Petitioner has relied on energy
exchange and over-drawl from the Grid (UI).

For projecting of the energy availability for FY 2020-21, six months actual power purchase has been considered
by the Petitioner in its Petition. For projection of remaining six months of power purchase for FY 2020-21, firm
and infirm allocation from various generating stations has been considered as per the allocation specified in the
notification no. WRPC/Comml-I/6/Alloc/2020 dated: 15/10/2020 of Western Regional Power Committee as
shown in the following table:

Table 44: Energy allocation as considered by the Petitioner for FY 2020-21 (MW)
Weighted average Weighted Average Weighted average
Name of the plant Infirm allocation Firm allocation total allocation
KSTPP 51.20 0.00 51.20
KSTPS -3 19.68 2.20 21.88
VSTPP-I 37.03 5.00 42.03
VSTPP-II 27.97 4.00 31.97
VSTPP- III 27.97 6.00 33.97
VSTPP- IV 39.36 5.55 44.91
KAWAS 56.18 25.00 81.18
GGPP 56.74 2.00 58.74
Sipat – I 77.93 9.00 86.93
Sipat – II 26.56 4.00 30.56
KHSTPP – II 3.50 0.00 3.50
Mauda I (MSTPS) 39.36 5.55 44.91
VSTPP-V 19.68 5.55 25.23
Mauda II 51.95 8.60 60.55
Solapur 51.95 21.57 73.52
Gadarwara 31.49 10.42 41.91

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 71
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Weighted average Weighted Average Weighted average


Name of the plant Infirm allocation Firm allocation total allocation
NPCIL – KAPS 10.36 2.00 12.36
NPCIL - TAPS 3&4 35.03 7.00 42.03
Total 747.07 145.50 892.57
NSPCL Bhilai 100.00 100.00

Commission’s Analysis:

The data pertaining to actual power purchase quantum for the period from October 2020 to December 2o20
was sought from the Petitioner. The Commission considered the data for first nine months of FY 2020-21 as
submitted by the Petitioner and estimated the power purchase quantum for the remaining months of the
financial year considering data of the firm and infirm allocation from various generating stations. The source
wise methodology followed for estimation of quantum of power procurement has been detailed as follows:

Availability of energy from NTPC Stations:


• Actual Power Purchase Quantum is available for first 9 months for FY 2020-21. From January to March
2021, power purchase quantum for 17 of the total 24 NTPC plants has been estimated based on 3 years
average (FY 2017-18 FY 2018-19 and FY 2019-20) of quantum of energy purchased from the respective
station during these months.

• For NTPC Mauda 2, Solarpur, Lara & Gadarwara for the power purchase quantum for January-March
2021 the Commission has considered the Petitioner’s estimation of power purchase for entire year due
to irregular scheduling of power from these stations. The actual power purchase of first 9 months is
subtracted from total Power Purchase quantum submitted by the petitioner. Remaining value of Power
Purchase quantum from each plant is equally distributed in last 3 months of the FY to arrive at the
month wise quantum purchased for FY 2020-21

• For NTPC Khargone, the power procurement for each month (January, February & March 2021) is
considered equal to average of power procurement in six months of FY 2020-21 (July 2020 to
December 2020) as there was no power is purchased in first three month (April 2020 to June 2020) of
the FY 2020-21 as it is a new plant.

Availability of energy from NSPCL Bhilai station:


• Actual Power Purchase Quantum is available for first 9 months for FY 2020-21. From January to March
2021, the Commission has considered power purchase quantum same as the petitioner’s estimation
since in FY 2019-20 the power procurement had drastically reduced from previous two years. The
actual power purchase of first 9 months is subtracted from total Power Purchase quantum submitted by
the petitioner. Remaining value of Power Purchase quantum from each plant is equally distributed in
last 3 months to arrive at the month wise quantum purchased for FY 2020-21

Availability from NPCIL stations:

• DNHPDCL receive supply from two NPCIL stations - Tarapur and Kakrapara atomic plants. The total
power purchase for the year from these sources is considered at same level as that projected by the
Petitioner.

Availability of power from the Open Market, Unscheduled Interchange and Banking

• The Open market purchase of 361.75 MUs for first 9 months has been considered as per actuals. For the
remaining months the quantum for purchase/sale has been considered as 101.99 MUs as estimated in
the energy balance, discussed in the previous section.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 72
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

• Quantum under UI Overdrawal/ Underdrawal for first 9 months of FY 2020-21 has been considered as
24.13 MUs as per actuals. Further due to availability of Power from firm and other sources, no quantum
is approved under UI Overdrawal by the Commission for last quarter (January-March) of FY 2020-21.

4.7.2. Power Purchase Cost


Petitioner’s submission:

Based on the actual power purchase cost of the first six months of FY 2020-21 and the remaining six months’
projection, the revised estimated power purchase cost for FY 2020-21 as submitted by the Petitioner is
presented in the following table:

Table 45: Power Purchase Quantum (MU) and Cost (INR Crore) submitted by Petitioner for FY 2020-21
All Per
Units Fixed Variable Other
Source Rebate Charges Unit
Purchased Charges Charges Charges
Total Cost
NTPC Stations
KSTPP 1&2 362.67 21.83 56.53 -0.82 0.00 77.54 2.14
KSTPS 3 163.93 20.10 25.32 -0.29 0.00 45.13 2.75
VSTPP-I 257.12 19.83 46.52 -1.00 0.00 65.35 2.54
VSTPP-II 208.62 13.22 36.69 -0.43 0.00 49.47 2.37
VSTPP- III 229.60 21.80 40.44 -0.90 0.00 61.34 2.67
VSTPP- IV 298.17 45.77 50.93 -0.25 0.00 96.44 3.23
KAWAS 202.23 47.99 42.08 3.00 0.00 93.07 4.60
JGPP 164.52 44.38 35.56 2.78 0.00 82.72 5.03
Sipat-I 614.68 72.71 100.62 -0.29 0.00 173.03 2.82
Sipat-II 215.11 23.44 36.41 -0.82 0.00 59.03 2.74
MSTPL 1 111.88 55.86 33.53 0.87 0.00 90.26 8.07
VSTPS-V 163.91 26.50 29.13 -0.29 0.00 55.34 3.38
Mauda 2 126.30 59.60 38.69 1.25 0.00 99.53 7.88
Solapur 199.51 84.68 59.81 0.49 0.00 144.97 7.27
LARA 184.82 46.10 39.36 -0.06 0.00 85.39 4.62
Gadarwara 204.90 55.63 53.68 0.18 0.00 109.49 5.34
BARH 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Dhuwaran 289.88 96.32 84.00 0.30 0.00 180.61 6.23
Kharagaon 0.00 0.00 0.00 0.00 0.00 0.00 0.00
FSTPS 0.00 0.00 0.00 0.00 0.00 0.00 0.00
KhSTPS I 0.00 0.00 0.00 0.00 0.00 0.00 0.00
RSTPS 0.00 0.00 0.00 0.00 0.00 0.00 0.00
TSTPS 0.00 0.00 0.00 0.00 0.00 0.00 0.00
KHSTPP-II 18.15 1.82 3.92 0.02 0.00 5.76 3.17
Subtotal 4,016.02 757.58 813.19 3.69 48.99 1,525.47 3.80
NSPCL - Bhilai 580.44 115.38 154.68 -1.31 0.00 268.75 4.63
NSPCL -
Rourkela

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 73
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

All Per
Units Fixed Variable Other
Source Rebate Charges Unit
Purchased Charges Charges Charges
Total Cost
NPCIL
KAPS 80.59 0.00 19.11 0.00 9.11 10.00 1.24
TAPS 3&4 288.22 0.00 99.96 44.54 0.00 144.50 5.01
Subtotal 368.82 0.00 119.07 44.54 9.11 154.50 4.19
Power
purchase from
Other Sources
Indian E.
Exchange/Bilater 646.55 0.00 218.97 0.00 0.00 218.97 3.39
al
UI 11.73 0.00 3.69 0.00 0.00 3.69 3.15
Solar 6.18 0.00 0.00 0.00 0.00 0.00 0.00
Non Solar 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Solar REC 0.00 0.00 36.37 0.00 0.00 36.37 0.00
Non Solar REC 0.00 0.00 48.65 0.00 0.00 48.65 0.00
Solar (SECI) 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Wind (SECI) 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Subtotal 664.46 0.00 307.68 0.00 0.00 307.68 4.63
Misc. Arrears
Power
5,630 873 1,395 47 58.10 2,256 4.01
Purchase Cost
Availability at
ED-DNH 5629.73 872.96 1394.62 46.92 58.10* 2256.40
Periphery
PGCIL
399.47
CHARGES
POSOCO 0.56
Reactive charges 2.43
Others 41.45
Grand Total of
5,629.73 872.96 1,394.62 46.92 2,700.30
Charges
GMR - Change
6.64
in Law
Total PP Cost 2,706.94

* As informed by the petitioner this total Rebate includes Rebate for early payment for NTPC/NPCIL plants and also includes Rebate
due to COVID-19 provided by NTPC, NSPCL & Power Grid.

Commission’s Analysis:

The data pertaining to power purchase cost for the period from October to December 2o20 was sought from the
Petitioner. The Commission considered the data for first nine months of FY 2020-21 as submitted by the
Petitioner and estimated the power purchase cost for the remaining months of the year considering data of the
firm and infirm allocation from various generating stations. The source wise methodology followed for
estimation of cost of power procurement has been detailed as follows:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 74
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Variable Charges:

• The per unit variable costs for various power stations, UI Over-drawal/ Under-drawal and Open Market
have been computed by taking the average of the actual per unit variable cost during the first 9 months
from April 2020 to December 2020 for all the stations.
Fixed Charges:
• Actual Fixed Costs have been considered for the first nine months for all stations for FY 2020-21.
• The fixed costs for the remaining months of the FY have been considered based on the Tariff Orders
issued by the CERC for respective Central Generating Stations.
• The remaining fixed cost, after deducting the fixed cost already paid by the Petitioner during first nine
months from the Annual Fixed Cost share of Petitioner for a plant for whole year has been considered
for the period January to March 2021.

• For few plants like NTPC Khargone, Gadarwara Kahalgaon and Solapur, fixed cost for January 2020 to
March 2020 has been calculated in proportion to actual fixed cost in first nine months of FY 2020-21.

Other Charges:

• Actual charges have been considered for the first 9 months of FY 2020-21. No other charges have been
considered for the remaining months of FY 2020-21.
Rebate (COVID-19):

In view of the prevailing conditions of COVID-19 pandemic in the country and the difficulties faced by various
sections of society, MoP vide letter dated 15.05.2020 & Corrigendum dtd 16.05.2020 decided that all Central
Public Sector Generating Companies under MoP and Central Public Sector Transmission Company may
consider to offer Rebate to Discoms as specified in the aforementioned letters. In accordance with the same,
DNHPDCL has been offered rebate by the following:

• NTPC: NTPC has decided to pass a Rebate of Rs. 23.29 Crore on capacity charges billed for lockdown
period due to COVID-19.
• Power Grid: Power grid has decided to offer a one-time consolidated rebate of Rs. 14.42 Cr against
the ISTS charges for the months of Apr’20 and May’20.

• NSPCL: NSPCL has decided to pass a Rebate of Rs. 3.69 Crore on capacity charges billed for lockdown
period due to COVID-19.
The Commission has considered this rebate while approving the power purchase cost for FY 2020-21.
Change in law (GMR) Expenses:
• The Petitioner has claimed Rs 6.64 Cr under Change in law by GMR. The Commission verified from the
supplementary invoices (issued by GMR to petitioner) submitted by Petitioner and observed that the
invoices are amounting to Rs 6.40 Cr only. Accordingly, the Commission has approved INR 6.40 Crore
under Change in law claims by GMR.
• As already discussed in Section 3.8, these claims are based on the multiple orders issued by the Central
Electricity Regulatory Commission (CERC).

4.7.3. Transmission Charges


Petitioner’s submission:

For PGCIL charges the Corporation has received bills amounting to INR 351.20 Crore during the first nine
months of FY 2020-21. Accordingly, DNHPDCL has projected the POC charges for the FY 2020-21 at INR
399.47 Crore.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 75
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis:

The Commission has estimated the transmission charges payable to PGCIL, WRLDC & MSTCL for FY 2020-21
based on the actual transmission charges paid in the first nine months of the financial year and transmission
charges for the remaining months of the FY have been considered based on the average of the actual
transmission charges paid in the first nine months. The same shall be trued-up as per actuals.

4.7.4. Total power purchase quantum and cost approved by Commission


The following table provides the quantum of energy availability and the power purchase cost approved by the
Commission for FY 2020-21:

Table 46: Power Purchase Quantum (MU) and cost (INR Crore) approved by the Commission for FY 2020-21
Fixed Variable Other Total Per
S. Energy
Charges Charges Charges# Charges Unit
No Source Units
(INR (INR (INR (INR (INR/
. (MU)
Crore) Crore) Crore) Crore) kwh)
A NTPC
1 KSTPS 358.05 24.43 55.20 -0.53 79.10 2.21
2 KSTPS 3 172.26 21.40 26.69 -0.16 47.93 2.78
3 VSTPP-I 255.97 24.43 44.53 -0.79 68.17 2.66
4 VSTPP-II 210.49 15.61 34.86 -0.26 50.21 2.39
5 VSTPP- III 240.77 25.01 40.69 -0.71 64.99 2.70
6 VSTPP- IV 317.35 49.62 52.43 -0.02 102.03 3.22
7 KGPP 202.23 50.34 38.58 3.11 92.03 4.55
8 GGPP 164.52 45.08 34.47 2.79 82.34 5.00
9 Sipat-I 613.11 80.08 95.17 -0.48 174.76 2.85
10 Sipat-II 202.16 26.65 31.89 -0.92 57.62 2.85
11 Mauda 154.72 59.04 42.80 1.45 103.29 6.68
12 VSTPS-V 172.21 29.44 29.64 -0.15 58.93 3.42
13 Mauda 2 126.30 60.43 36.74 1.65 98.82 7.82
14 Solapur 199.51 84.68 57.68 0.90 143.25 7.18
15 LARA 184.82 61.08 38.86 0.23 100.16 5.42
16 Gadarwara 204.90 56.38 52.76 0.02 109.16 5.33
17 BARH 0.00 - - 0.00 0.00 0.00
18 Kharagaon 285.14 83.87 79.51 0.63 164.01 5.75
19 KHSTPP-II 16.39 1.72 3.51 0.09 5.32 3.24
Subtotal – NTPC 4080.91 799.27 796.00 6.86 1602.13 3.93

B NSPCL – Bhilai 580.44 116.66 150.54 0.43 267.64 4.61

C NPCIL
1 KAPS 80.59 - 18.61 0.00 18.61 2.31
2 TAPS 288.22 - 97.74 44.54 142.28 4.94
Subtotal 368.82 0.00 116.35 44.54 160.89 4.36
Total of all Firm
5030.16 915.93 1062.90 51.83 2030.66 4.04
Sources
E Other Sources
Energy Exchange/
1
Bilateral 463.74 0.00 133.40 0.00 133.40 2.88
2 UI 24.13 0.00 7.32 0.00 7.32 3.03
3 Solar* 25.95 0.00 9.61 0.00 9.61 3.70
4 Non Solar 2.30 0.00 0.82 0.00 0.82 3.55

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 76
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Fixed Variable Other Total Per


S. Energy
Charges Charges Charges# Charges Unit
No Source Units
(INR (INR (INR (INR (INR/
. (MU)
Crore) Crore) Crore) Crore) kwh)
5 Solar REC 0.00 0.00 0.00 0.00 0.00 0.00
6 Non Solar REC 0.00 0.00 0.00 0.00 0.00 0.00
7 Solar SECI 0.00 0.00 0.00 0.00 0.00 0.00
8 Wind SECI 0.00 0.00 0.00 0.00 0.00 0.00
9 Own Solar 6.18 0.00 0.00 0.00 0.00 0.00
Subtotal - Other
522.31 0.00 151.14 0.00 151.14 2.89
Sources
Total 5552.47 915.93 1214.04 51.83 2181.80 3.93

F Charges
1 PGCIL CHARGES 468.27
2 POSOCO 0.54
3 WRPC 0.00
4 Reactive charges 1.63
5 MSTCL 0.00
Intra-state
6 transmission 27.63
charges
Grand Total of
G 2679.87
Charges
GMR Change in
H 6.40
Law
Early payment
I -16.46
Rebate
Power Grid -
J -14.42
Rebate COVID-19
NTPC Limited -
K -23.29
Rebate COVID-19
NSPCL - Rebate
L -3.69
COVID-19
Total Charges &
M 5,552.47 915.93 1214.04 51.83 2628.41 4.73
Quantum
* The details and cost for RPO is provided in Section 4.8
# Other Charges includes ED & Cess on APC/Sales, Energy Charges Revision, ECR Gain Sharing, Insurance charges, Nuclear Liability
Fund, sharing of benefits etc.

The Commission approves the revised quantum of power purchase as 5,552.47 MU at the
generator periphery with total cost of INR 2,628.41 Crore in the APR for FY 2020-21.

Renewable Purchase Obligation (RPO)


Petitioner’s submission:

As per the revised sales projections, the Petitioner has estimated requirement of 314.39 MUs of solar energy
and 412.32 MUs of non-solar energy during FY 2020-21 to fulfill the RPO targets. The DNHPDCL plans to
generate 6.18 MUs of solar power through its own Solar generation plant. The Petitioner submitted that the rest
of the RPO shall be fulfilled by purchase of Renewable Energy Certificates.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 77
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis:

Clause 1, Sub-clause (1) of the JERC for the State of Goa and UTs (Procurement of Renewable Energy)
Regulations, 2010 provides:

“(1.1) Each distribution licensee shall purchase electricity (in kWh) from renewable energy sources, at a
defined minimum percentage of the total consumption of all the consumers in its area during a year.”

Further, the Commission notified the JERC (Procurement of Renewable Energy), (Third Amendment)
Regulations, 2016 on August 22, 2016 and approved the revised RPO targets, as per which the Petitioner has to
purchase 14.10% of its total consumption through conventional sources (Solar: 6.10% and non-solar: 8.00%)
from renewable sources for FY 2020-21. This translates to the requirement of procurement of 313.72 MU of
solar energy and 411.43 MUs of non-solar energy in FY 2020-21.

Also the Petitioner is required to clear the backlog of 675.33 MU (Solar: 263.71 MU and Non-Solar: 411.62 MU)
up to FY 2019-20 that has been carried forward.

The Commission asked the Petitioner to submit the details of actual RPO met from April 2020 to December
2020 and the Petitioner submitted the details of actual RPO met during the period April 2020 to December
2020 as follows:

• Solar – 25.95 MU

• Non-Solar – 2.30 MU

• Own Solar- 4.64 MU

The Commission asked the Petitioner to submit the details of actual RECs purchased from April 2020 to
December 2020. In reply, the Petitioner submitted that it has not purchased any REC’s.

In accordance with the JERC (Procurement of Renewable Energy) Regulations, 2010 and the Petitioner’s
submission, the Commission has determined the following Renewable Purchase Obligation for the Petitioner
for FY 2020-21 as shown below:

Table 47: Summary of Renewable Purchase Obligation (RPO) for FY 2020-21 (MU)

Sr. No. Particulars Formulae Value

A Solar Target 6.10%


B Non-Solar Target 8.00%
C Total RPO Target C=A+B 14.10%

D Sales Within UT 5142.89

E RPO Obligation for the year E=F+G 725.15


F Solar F=D*A 313.72
G Non-Solar G=D*B 411.43

H Physical RE Purchase (till Jan 2020) H=I+J 34.43


I Solar 32.13
J Non-Solar 2.30

K REC Purchase (till December 2020) K=L+M 0.00

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 78
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Sr. No. Particulars Formulae Value

L Solar 0.00
M Non-Solar 0.00

N Total RPO Compliance for FY 2020-21 (REC+ Physical RE) N=O+P 34.43
O Solar O=I+L 32.13
P Non-Solar P=J+M 2.30

Q Standalone shortfall for FY 2020-21 690.72


R - Solar R=F-O 281.59
S - Non-Solar S=G-P 409.13

T Backlog upto FY 2019-20 T=U+V 675.33


U - Solar 263.71
V - Non-Solar 411.62

W Total Shortfall in RPO Compliance for FY 2020-21 W=X+Y 1,366.05


X Solar X=R+U 545.30
Y Non-Solar Y=S+V 820.75

The Commission has computed the cost towards compliance of RPO. The Commission has considered actual
purchase for FY 2020-21 till Jan 2021, based on the information provided by the Petitioner. Trading of RECs
was suspended in July 2020 after the Appellate Tribunal for Electricity (APTEL) decided to postpone the
trading by four weeks while hearing three separate petitions related to issue of fixing floor and forbearance
prices of RECs by the Central Electricity Regulatory Commission (CERC). Later, the trading was not resumed as
APTEL directed to enforce the interim order on suspension of REC trade till final judgment. Accordingly, the
Commission has considered actual numbers as submitted by the petitioner and not considered any cost towards
meeting shortfall of RPO target.

The Commission also feels that the petitioner has failed to cover not only the entire RPO shortfall till FY 2020-
21 but also the standalone RPO target set for the year. Accordingly, the Commission directs the petitioner
to fulfill the RPO obligation in future years by either purchasing power from Renewable energy
sources or by purchasing RECs.

The Commission will consider the actual cost incurred towards meeting RPO at the time of truing up subject to
prudence check.

The Commission has computed the cost towards compliance of RPO as shown in the following table:

Table 48: Cost towards compliance of Renewable Purchase Obligation for FY 2020-21 (INR Crore)
RPO Total Cost Avg. Rate
S. No Description
(MU) (INR Crore) (INR/kWh)
1 Solar
(a) Generation 25.95 9.61 3.70
(b) Renewable Energy Certificates 0.00 0.00 -
(c) Own Solar 6.18 0.00 -
2 Non-solar

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 79
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

RPO Total Cost Avg. Rate


S. No Description
(MU) (INR Crore) (INR/kWh)
(a) Generation/Procurement 2.30 0.82 3.55
(b) Renewable Energy Certificates 0.00 0.00 -
Total 34.43 10.43 3.02

The Commission approves INR 10.43 Crore towards compliance of RPO in the APR of FY 2020-
21 and the same has been considered in the total power purchase cost approved for FY 2020-21.

Operation & Maintenance Expenses


The Operation & Maintenance Expenses comprises of the Employee Expenses, Administrative and General
Expenses (A&G) and the Repair & Maintenance Expenses (R&M). The MYT Regulations, 2018 recognize the
variation of O&M Expenses to be controllable.

Regulation 12.2 of the MYT Regulation, 2018, which recognizes O&M expenses as controllable, states the
following:

“12.2 For the purpose of these Regulations, the term “controllable factors” for a Transmission or Distribution
Licensee shall comprise of the factors which were within the control of the Licensee, shall inter-alia include:
a) Variations in capitalization on account of time and/or cost overruns/ efficiencies in the implementation of
a capital expenditure project not attributable to an approved change in scope of such project, change in
statutory levies or force majeure events;
b) Variation in Interest and Finance Charges, Return on Equity, and Depreciation on account of variation in
capitalization, as specified in clause (a) above;
c) Variations in technical and commercial losses of Distribution Licensee;
d) Availability of transmission system;
e) Variations in performance parameters;
f) Failure to meet the standards specified in the Joint Electricity Regulatory Commission for the State of
Goa & UTs (Standard of Performance for Distribution Licensees) Regulation, 2015, as amended from
time to time;
g) Variations in labor productivity;
h) Variation in O&M Expenses, except to the extent of inflation;
……..”
The Operation & Maintenance Expenses comprises of the Employee Expenses, Administrative and General
Expenses (A&G) and the Repair & Maintenance Expenses (R&M).

Regulation 51 of the MYT Regulation, 2018 states the following:

“51.1 The Operation and Maintenance expenses for the Distribution Wires Business shall be computed in
accordance with this Regulation.
51.2 Operation and Maintenance (O&M) expenses shall comprise of the following:
a) Employee expenses - salaries, wages, pension contribution and other employee costs;
b) Administrative and General expenses including insurance charges if any; and
c) Repairs and Maintenance expenses.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 80
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

51.3 The Distribution Licensee shall submit the required O&M expenses for the Control Period as a part of
Multi Year Tariff Petition. O&M expenses for the base Year shall be approved by the Commission taking into
account the latest available audited accounts, business plan filed by the transmission Licensee, estimates of
the actuals for the Base Year, prudence check and any other factors considered appropriate by the
Commission.
51.4 O&M expenses for the nth Year of the Control Period shall be approved based on the formula given
below:
O&Mn = (R&Mn + EMPn + A&Gn) x (1 - Xn) + Terminal Liabilities
Where,
R&Mn = K x GFAn-1 x (WPI inflation)
EMPn = (EMPn-1) x (1+Gn) x (CPI inflation)
A&Gn = (A&Gn-1) x (CPI inflation)
‘K’ is a constant (expressed in %). Value of K for each Year of the Control Period shall be
determined by the Commission in the Multi Year Tariff Order based on Licensee’s filing,
benchmarking of repair and maintenance expenses, approved repair and maintenance
expenses vis-à-vis GFA approved by the Commission in past and any other factor considered
appropriate by the Commission;
CPI inflation – is the average increase in Consumer Price Index (CPI) for immediately preceding three (3)
Years before the base Year;
WPI inflation – is the average increase in the Wholesale Price Index (CPI) for immediately preceding three (3)
Years before the base Year;
EMPn – Employee expenses of the Distribution Licensee for the nth Year;
A&Gn – Administrative and General Expenses of the Distribution Licensee for the nth Year;
R&Mn – Repair and Maintenance expenses of the Distribution Licensee for the nth Year;
GFAn-1 – Gross Fixed Asset of the transmission Licensee for the n-1th Year;
Xn is an efficiency factor for nth Year. Value of Xn shall be determined by the Commission in the Multi Year
Tariff Order based on Licensee’s filing, benchmarking, approved cost by the Commission in past and any
other factor the Commission feels appropriate;
Gn is a growth factor for the nth Year. Value of Gn shall be determined by the Commission for each Year in
the Multi Year Tariff Order for meeting the additional manpower requirement based on Licensee’s filings,
benchmarking, and approved cost by the Commission in past and any other factor that the Commission feels
appropriate:
Provided that in case the Distribution Licensee has been in operation for less than three (3) Years as on the
date of effectiveness of these Regulations, O&M Expenses shall be determined on case to case basis.
51.5 Terminal liabilities of employees of Licensee including pension expenses etc. shall be approved as per
actuals submitted by the Licensee, subject to prudence check or be established through actuarial studies.
Additionally, any variation due to changes recommended by the pay commission shall be allowed separately
by the Commission, subject to prudence check.
51.6 For the purpose of estimation, the same value of factors – CPI inflation and WPI inflation
shall be used for all Years of the Control Period. However, the Commission shall consider the actual
values of the factors – CPI inflation and WPI inflation during the truing up exercise for the Year for which
true up is being carried out and true up the O&M Expenses for that Year, only to the extent of inflation.”
(Emphasis supplied)

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 81
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

4.9.1. Employee Expenses


Petitioner’s submission

The Petitioner has submitted revised estimate for employee expenses of INR 13.65 Crore for FY 2020-21 against
INR 13.41 Cr as approved by the Commission in the ARR Order of FY 2020-21.
Commission’s Analysis

In accordance with the MYT Regulations, 2018, the Commission has determined the Employee expenses for FY
2020-21. The Regulation 6 of the MYT Regulations, 2018 specifies the following:

“6. Values for Base Year

6.1 The values for the Base Year of the Control Period shall be determined on the basis of the audited accounts
or provisional accounts of last three (3) Years, and other factors considered relevant by the Commission:

Provided that, in absence of availability of audited accounts or provisional accounts of last three (3) Years,
the Commission may benchmark the parameters with other similar utilities to establish the values for Base
Year:

Provided, further that the Commission may change the values for Base Year and consequently the trajectory
of parameters for Control Period, considering the actual figures from audited accounts.

……..”

As shown above, Regulation 6 provides that the Commission may change the values for Base Year considering
the actual figures from audited accounts. As the Commission in this Order has carried out the truing up for FY
2019-20 based on audited accounts, the Commission has considered the trued-up employee expenses for FY
2019-20 as base expenses and applied the CPI Inflation for approving the revised employee expenses for FY
2020-21.
The CPI Inflation has been computed as follows:

Table 49: Average CPI Inflation Rate (%)


Increase in CPI Average increase in CPI
FY Average of (Apr-Mar)
Index indices over 3 years
2017-18 284.58 3.14%
2018-19 299.92 5.39%
2019-20 322.50 7.53%
CPI Inflation 5.35%

As per the details submitted by the Petitioner in the Petition, the estimated growth in number of employees for
FY 2020-21 is -0.80%. Hence, the Commission has considered the revised growth in employee expenses for FY
2020-21 while projecting the employee expenses for FY 2020-21. The following table provides Employee
expenses approved by the Commission for FY 2020-21:

Table 50: Employee Expenses approved by Commission for FY 2020-21 (INR Crore)
S. Approved in Petitioner's Now Approved
Particulars
No ARR Order Submission by Commission
1 Employee Expenses of previous year (EMPn-1) 12.83 13.34
2 Growth in number of employees (Gn) 0.27% - -0.80%
3 CPI Inflation for preceding three years (CPI) 4.22% 5.35%
Employee Expenses
4 (EMPn) = (EMPn-1)x(1+Gn)x(1+ CPI inflation) 13.41 13.65 13.95

The Commission approves employee expenses of INR 13.95 Crore in the APR of FY 2020-21.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 82
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

4.9.2. Administrative and General (A&G) Expenses

Petitioner’s submission

The Petitioner has submitted revised estimate of INR 7.70 Crore towards A&G expenses against INR 6.34 Cr as
approved by the Commission in the Tariff Order of FY 2020-21.

Commission’s Analysis

Similar to the methodology followed while estimating the employee expenses, the Commission has considered
the trued-up A&G expenses for FY 2019-20 as Base Year expenses and escalated the same with CPI Inflation for
approving the revised trajectory of A&G expenses for FY 2020-21 as shown in the following table:

Table 51: A&G Expenses approved by Commission for FY 2020-21 (INR Crore)
S. Approved in Petitioner's Now Approved by
Particulars
No ARR Order Submission Commission
A&G Expense for the previous
1 5.84 7.31 6.28
year (A&Gn-1)
CPI Inflation for preceding three
2 4.22% 5.35% 5.35%
years (CPI)
Administration & General
3 Expenses (A&Gn) = (A&Gn-1) 6.34 7.70 6.62
x (1+CPI inflation)

The Commission now approves the Administrative & General (A&G) expenses of INR 6.62 Crore
in the APR for FY 2020-21.

4.9.3. Repair & Maintenance Expenses (R&M)

Petitioner’s submission

The Petitioner has submitted revised estimate of INR 22.41 Crore towards R&M expenses against INR 11.53
Crore approved by the Commission in the ARR Order of FY 2020-21.

Commission’s Analysis

As shown above and as provided in clause 51.4 of the JERC MYT Regulations, 2018, the Commissions has
considered the same value of ‘K’ factor, i.e., 2.03% which was approved by the Commission in MYT order dated
20th May 2019 for FY 2020-21.

Further, as provided in Regulations 51.6, the WPI Inflation has been computed as follows:
Table 52: Computation of WPI Inflation (%)

Increase in WPI Average increase in WPI


FY Average of (Apr-Mar)
Index indices over 3 years
2017-18 114.88 2.92%
2018-19 119.79 4.28%
2019-20 121.80 1.68%
WPI Inflation 2.96%

Further the approved closing GFA for the FY 2019-20 have been considered for computation of R&M expenses
for FY 2020-21. Hence, the R&M expenses approved by the Commission for FY 2020-21 are as provided in the
following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 83
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Table 53: R&M approved by the Commission for FY 2020-21

S. No Particulars Value
1 GFA (GFAn-1) of the previous year 466.84
2 K factor approved (K) 2.03%
3 WPI Inflation 2.96%
R&M Expenses = (K x (GFA n-1) x (1+WPIinflation) 9.76

The Commission approves the Repair & Maintenance (R&M) expenses of INR 9.76 Crore in the
APR of FY 2020-21.

4.9.4. Total Operation and Maintenance Expenses (O&M)

The following table provides the O&M expenses approved by the Commission in the ARR Order, Petitioner’s
submission and O&M expenses now approved by the Commission:

Table 54: O&M Expenses approved by Commission for FY 2020-21 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 Employee Expenses 13.41 13.65 13.95
Administrative & General Expenses
2 6.34 7.70 6.62
(A&G)
3 Repair & Maintenance Expenses 11.53 22.41 9.76
Total Operation &
31.28 43.76 30.32
Maintenance Expenses

The Commission approves the Operation & Maintenance (O&M) expenses of INR 30.32 Crore in
the APR of FY 2020-21.

Gross Fixed Assets (GFA) and Capitalization


Petitioner’s submission

The Petitioner has considered the capital expenditure & capitalization at the same level as approved by the
Commission for FY 2020-21 in its ARR Order.

Commission’s Analysis

The Petitioner has proposed the same capital expenditure and capitalization as approved by the Commission in
its ARR Order dated May 18, 2020. The Commission through a deficiency note directed petitioner to submit
details like physical progress, financial progress and expected completion date for scheme(s) proposed to be
capitalized in FY 2020-21. The Petitioner submitted that the scheme “Establishment on Turnkey Basis of
66/11kV GIS substation at Zanda Chawk Silvassa with associated 66kV Underground Transmission Line &
11kV /LT Underground Distribution Network for Silvassa City with Operation & Maintenance of above
installation for the period of 5 years” will be capitalized in FY 2020-21 as the scheme is completed and only
electrical certificate for this scheme is awaited. The cost of this project is INR 158.96 Cr.

Accordingly, the Commission at this stage has only considered the scheme which is likely to be capitalised in FY
2020-21 as shown in Table below:

Table 55: Capitalization approved by the Commission for FY 2020-21 (INR Crore)
Approved in Petitioner's Now Approved by
S. No Particulars
ARR Order Submission Commission
1 Capital Expenditure 30.19 30.19 30.19
2 Capitalization 182.69 182.69 158.69

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 84
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

The Commission approves capital expenditure of INR 30.19 Crore and Capitalization of INR
158.69 Crore in the APR for FY 2020-21.

Capital Structure
Petitioner’s Submission

The petitioner has submitted that the entire capital deployment shall be through equity for FY 2020-21.

Commission’s Analysis

The MYT Regulations, 2018 specifies that if the equity actually deployed is more than 30% of the capital cost,
then equity in excess of 30% would be considered as normative loan. Regulation 26 of the MYT Regulations
2018 states the following:

“26. Debt to Equity Ratio

26.1 In case of Existing Projects, debt to equity ratio allowed by the Commission for determination of tariff for
the period ending March 31, 2018 shall be considered:

Provided that in case of retirement or replacement or De-capitalization of the assets, the equity capital
approved as mentioned above, shall be reduced to the extent of 30% (or actual equity component based on
documentary evidence, if it is lower than 30%) of the original cost of such assets:

Provided, further that in case of retirement or replacement or De-capitalization of the assets, the debt capital
approved as mentioned above, shall be reduced to the extent of outstanding debt component based on
documentary evidence, or the normative loan component, as the case may be, of the original cost of such
assets.

26.2 For New Projects, the debt-equity ratio as on the Date of Commercial Operation shall be 70:30 of the
amount of capital cost approved by the Commission under Regulation 23, after prudence check for
determination of tariff:

Provided that where equity actually deployed is less than 30% of the capital cost of the capitalized asset, the
actual equity shall be considered for determination of tariff:

Provided also that if the equity actually deployed is more than 30% of the capital cost, equity in excess of 30%
shall be treated as a normative loan for the Licensee for determination of tariff:

Provided also that the Licensee shall submit documentary evidence for the actual deployment of equity and
explain the source of funds for the equity:

Provided also that the equity invested in foreign currency shall be designated in Indian rupees on the date of
each investment:

Provided further that the premium, if any, raised by the Licensee while issuing share capital and investment
of internal resources created out of its free reserves, for the funding of the scheme, shall be reckoned as paid
up capital for the purpose of computing return on equity, provided such premium amount and internal
resources are actually utilized for meeting the capital expenditure of the transmission system or the
distribution system, and are within the ceiling of 30% of capital cost approved by the Commission.

26.3 Any expenditure incurred or projected to be incurred on or after April 1, 2019, as may be admitted by the
Commission, as additional capital expenditure for determination of tariff, and renovation and modernization
expenditure for life extension shall be serviced in the manner specified in this Regulation.”

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 85
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

In accordance with the above, since the Petitioner has submitted that the entire capitalization is funded through
equity, thus equity higher than 30% of capitalization has been considered as normative loan.

The opening Gross Fixed Assets for FY 2020-21 has been considered as closing Gross Fixed Assets approved in
true-up of FY 2019-20. Further the values of opening loan and equity has been considered as closing loan and
equity approved in true-up of FY 2019-20. The loan and equity addition have been considered on normative
basis as 70% and 30% respectively of the approved capitalization for the year.

Accordingly, the Commission approves the capital structure for FY 2020-21 as shown in the tables below:

Table 56: Funding Plan approved by the Commission for FY 2020-21 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 Capitalization 182.69 182.69 158.69
2 Debt (%) 70% 70% 70%
3 Equity (%) 30% 30% 30%
4 Normative Loan 127.88 127.88 111.08
5 Equity 54.81 54.81 47.61

Table 57: GFA addition approved by Commission for FY 2020-21 (INR Crore)
Approved in ARR Petitioner's Now Approved by
S. No Particulars
Order Submission Commission
1 Opening Gross Fixed Assets 458.06 466.84 466.84
2 Addition During FY 182.69 182.69 158.69
3 Adjustment/Retirement During FY 0.00 0.00 0.00
4 Closing Gross Fixed Assets 640.75 649.53 625.53

Table 58: Normative Loan addition for FY 2020-21 (INR Crore)


Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 Opening Normative Loan 14.34 25.42 20.11
Add: Normative Loan During the
2 127.88 127.88 111.08
year
Less: Normative Repayment
3 19.19 19.93 18.44
equivalent to Depreciation
4 Closing Normative Loan 123.03 133.38 112.75

Table 59: Normative Equity addition for FY 2020-21 (INR Crore)


Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 Opening Equity 101.79 140.05 104.42
Additions on account of new
2 54.81 54.81 47.61
capitalization
3 Closing Equity 156.60 194.86 152.03

Depreciation
Petitioner’s submission

For computation of depreciation, the closing GFA of FY 2019-20 is taken as the opening GFA for FY 2020-21
and subsequently the proposed capitalization during FY 2020-21 is added. Depreciation has been calculated
based on depreciation rates in accordance with the MYT Regulations, 2018.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 86
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

Regulation 30 of the MYT Regulations, 2018 specifies the following:

“30. Depreciation

30.1 The value base for the purpose of depreciation shall be the capital cost of the asset admitted by the
Commission:

Provided that the depreciation shall be allowed after reducing the approved original cost of the retired or
replaced or decapitalized assets:

Provided, also that the no depreciation shall be allowed on the assets financed through consumer
contribution, deposit work, capital subsidy or grant.

30.2 The salvage value of the asset shall be considered as 10% and depreciation shall be allowed up to a
maximum of 90% of the capital cost of the asset.

30.3 Land other than the land held under lease shall not be a depreciable asset and its cost shall be excluded
from the capital cost while computing depreciable value of the assets.

30.4 In case of existing assets, the balance depreciable value as on April 1, 2019, shall be worked out by
deducting the cumulative depreciation as admitted by the Commission up to March 31, 2018, from the gross
depreciable value of the assets.

30.5 The depreciation shall be chargeable from the first Year of commercial operations. In case of projected
commercial operation of the assets during the Year, depreciation shall be computed based on the average of
opening and closing value of assets:

Provided that depreciation shall be re-calculated during truing-up for assets capitalized at the time of truing
up of each Year of the Control Period, based on documentary evidence of asset capitalized by the Applicant,
subject to the prudence check of the Commission.

30.6 For Transmission Licensee, the depreciation shall be calculated at rates and norms specified in the
prevalent CERC Tariff Regulations for transmission system.

30.7 The depreciation for a Distribution Licensee shall be calculated annually, based on the Straight Line
Method, over the Useful Life of the asset at rates specified in Appendix I of the Regulations.

30.8 In addition to allowable depreciation, the Distribution Licensee shall be entitled to advance against
depreciation (AAD), computed in the manner given hereunder:

AAD = Loan (raised for capital expenditure) repayment amount based on loan repayment tenure, subject to a
ceiling of 1/10th of loan amount minus depreciation as calculated on the basis of these Regulations:

Provided that advance against depreciation shall be permitted only if the cumulative repayment upto a
particular Year exceeds the cumulative depreciation upto that Year:

Provided, further that advance against depreciation in a Year shall be restricted to the extent of difference
between cumulative repayment and cumulative depreciation upto that Year.

30.9 The Distribution Licensee shall provide the list of assets added during each Year of Control Period and
list of assets completing 90% of depreciation in the Year along with Petition for annual performance review,
true-up and tariff determination for ensuing Year.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 87
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

30.10 The remaining depreciable value for a Distribution Licensee shall be spread over the balance useful life
of the asset, on repayment of the entire loan.”

The Commission has considered the opening GFA, addition during the year and closing GFA as approved in
Section 4.10 and Section 4.11 of this Order. The depreciation has been computed on average Gross Fixed Assets
(GFA). Effective Depreciation rate has been computed by calculating asset wise depreciation with the
depreciation rates as specified in Appendix I of MYT Regulation, 2018.

The following table provides the calculation of deprecation during FY 2020-21:

Table 60: Depreciation approved by Commission for FY 2020-21 (INR Crore)


Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 Opening Gross Fixed Assets 458.06 466.84 466.84
2 Addition During FY 182.69 182.69 158.69
3 Adjustment/Retirement During FY 0.00 0.00 0.00
4 Closing Gross Fixed Assets 640.75 649.53 625.53
5 Average Gross Fixed Assets 549.40 558.19 546.18
6 Effective Rate of Depreciation (%) 3.49% - 3.38%
Depreciation 19.19 19.93 18.44

Accordingly, the Commission now approves depreciation of INR 18.44 Crore in the APR for FY
2020-21.

Interest on Loan
Petitioner’s submission

The Petitioner has calculated the Interest on Loan on normative basis according to the MYT Regulations, 2018.
The closing balance of FY 2019-20 is taken as the opening balance of loans for FY 2020-21. The normative loan
addition in FY 2020-21 has been computed as 70% of the capitalization proposed during FY 2020-21.

The repayment of loans has been considered equivalent to the depreciation during FY 2020-21. Further the rate
of interest has been considered as 9.55%.

Commission’s Analysis:

Regulation 28 of the MYT Regulations, 2018 provides:

“28. Interest on Loan

28.1 The loans arrived at in the manner indicated in Regulation 26 on the assets put to use, shall be
considered as gross normative loan for calculation of interest on the loan:

Provided that interest and finance charges on capital works in progress shall be excluded:

Provided, further that in case of De-capitalization or retirement or replacement of assets, the loan capital
shall be reduced to the extent of outstanding loan component of the original cost of the de-capitalized or
retired or replaced assets, based on documentary evidence.

28.2 The normative loan outstanding as on April 1, 2019, shall be worked out by deducting the cumulative
repayment as admitted by the Commission up to March 31, 2018, from the gross normative loan.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 88
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

28.3 Notwithstanding any moratorium period availed by the Transmission Licensee or the Distribution
Licensee, as the case may be, the repayment of loan shall be considered from the first Year of commercial
operation of the project and shall be equal to the annual depreciation allowed in accordance with Regulation
30.

28.4 The rate of interest shall be the weighted average rate of interest calculated on the basis of the actual
loan portfolio at the beginning of each Year applicable to the Transmission Licensee or the Distribution
Licensee:

Provided that at the time of truing up, the weighted average rate of interest calculated on the basis of the
actual loan portfolio during the Year applicable to the Transmission Licensee or the Distribution Licensee
shall be considered as the rate of interest:

Provided also that if there is no actual loan for a particular Year but normative loan is still outstanding, the
last available weighted average rate of interest for the actual loan shall be considered:

Provided further that if the Transmission Licensee or the Distribution Licensee does not have actual loan, then
one (1) Year State Bank of India (SBI) MCLR / any replacement thereof as notified by RBI for the time being
in effect applicable for one (1)Year period, as may be applicable as on 1st April of the relevant Year plus 100
basis points shall be considered as the rate of interest for the purpose of allowing the interest on the
normative loan.

28.5 The interest on loan shall be calculated on the normative average loan of the Year by applying the
weighted average rate of interest:

Provided that at the time of truing up, the normative average loan of the Year shall be considered on the basis
of the actual asset capitalization approved by the Commission for the Year.

28.6 For new loans proposed for each Financial Year of the Control Period, interest rate shall be considered
as lower of (i) one (1) Year State Bank of India (SBI) MCLR / any replacement thereof as notified by RBI for
the time being in effect applicable for one (1) Year period, as may be applicable as on 1st April of the relevant
Year plus 100 basis points, and (ii) weighted average rate of interest proposed by the Distribution Licensee.

28.7 The above interest computation shall exclude the interest on loan amount, normative or otherwise, to the
extent of capital cost funded by consumer contribution, deposit work, capital subsidy or grant, carried out by
Transmission Licensee or Distribution Licensee.

28.8 The finance charges incurred for obtaining loans from financial institutions for any Year shall be
allowed by the Commission at the time of Truing-up, subject to prudence check.

28.9 The excess interest during construction on account of time and/or cost overrun as compared to the
approved completion schedule and capital cost or on account of excess drawal of the debt funds
disproportionate to the actual requirement based on Scheme completion status, shall be allowed or disallowed
partly or fully on a case to case basis, after prudence check by the Commission:
Provided that where the excess interest during construction is on account of delay attributable to an agency
or contractor or supplier engaged by the Transmission Licensee, any liquidated damages recovered from
such agency or contractor or supplier shall be taken into account for computation of capital cost:
Provided further that the extent of liquidated damages to be considered shall depend on the amount of excess
interest during construction that has been allowed by the Commission.
28.10 The Transmission Licensee or the Distribution Licensee, as the case may be, shall make every effort to
re-finance the loan as long as it results in net savings on interest and in that event the costs associated with
such re-financing shall be borne by the beneficiaries and the net savings shall be shared between the equally
between the beneficiaries and the Transmission Licensee or the Distribution Licensee and the Consumers of
Distribution Licensee.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 89
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

28.11 Interest shall be allowed on the amount held as security deposit held in cash from Retail Consumers at
the Bank Rate as on 1st April of the Financial Year in which the Petition is filed:
Provided that at the time of truing-up, the interest on the amount of security deposit for the Year shall be
considered on the basis of the actual interest paid by the Licensee during the Year, subject to prudence check
by the Commission.”

The Commission has considered the values for opening loan and loan addition as approved in the Section 4.11:
Capital Structure of this Order. Further, the repayment is considered same as depreciation approved for the
year. In line with past practice, the Commission for the purpose of calculation of Interest on Loan has
considered the interest rate equivalent to 1-year SBI MCLR (as on 01.04.2020, i.e., 7.75%) plus 100 basis points
as rate of interest, in accordance with the MYT Regulations, 2018. The following table provides the Interest on
Loan approved by the Commission:

Table 61: Interest on Loan approved by Commission for FY 2020-21 (INR Crore)
S. Approved in Petitioner's Now Approved
Particulars
No ARR Order Submission by Commission
1 Opening Normative Loan 14.34 25.42 20.11
2 Add: Normative Loan During the year 127.88 127.88 111.08
3 Less: Normative Repayment = Depreciation 19.19 19.93 18.44
4 Closing Normative Loan 123.03 133.38 112.75
5 Average Normative Loan 68.69 79.40 66.43
6 Rate of Interest (%) 8.85% 9.55% 8.75%
Interest on Loan 6.08 6.95 5.81
The Interest on Loan approved by the Commission is lower in comparison to claimed by the petitioner is due to
less opening GFA which is closing GFA of previous year (FY 2019-20) and less Rate of interest has been
considered by the Commission is as per JERC MYT Regulations, 2018.

Accordingly, the Commission approves Interest on Loan of INR 5.81 Crore in the APR of FY
2020-21.

Return on Equity (RoE)


Petitioner’s Submission

The Return on Equity (RoE) is computed in accordance with the MYT Regulations 2018, and the average equity
is segregated into Distribution wires business and retails supply business based on allocation statement
provided in MYT regulation 2018. The Petitioner has considered the rate of Return on Equity as 15.50% for
distribution wires business and 16.00% for retail supply business.

Commission’s Analysis:

In this regard the Regulation 27.2 and 27.3 of the MYT Regulations, 2018 specifies the following:

“27.2 The return on equity for the Distribution Wires Business shall be allowed on the equity capital
determined in accordance with Regulation 26 for the assets put to use at post-tax rate of return on equity
specified in the prevalent CERC Tariff Regulations for transmission system.

27.3 The return on equity for the Retail Supply Business shall be allowed on the equity capital determined in
accordance with Regulation 26 for the assets put to use, at the rate of sixteen (16) per cent per annum.”

(Emphasis supplied)

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 90
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Further, in this regard, the Regulation 30(2) of the CERC (Terms and Conditions of Tariff) Regulations, 2019
stipulates the following:

“30. Return on Equity:

………

30.2 Return on equity shall be computed at the base rate of 15.50% for thermal generating station,
transmission system including communication system and run-of river hydro generating station, and at
the base rate of 16.50% for the storage type hydro generating stations including pumped storage hydro
generating stations and run-of river generating station with pondage:
……..” (Emphasis supplied)

The Commission has segregated the approved average equity (average of opening and closing equity) into
average equity for Distribution Wires Business and Retail Supply Business based on the Allocation Statement
provided in the MYT Regulations, 2018, i.e., 90% allocation for the Distribution Wires Business and 10%
allocation for the Retail Supply Business. The Commission has considered a rate of 15.50% for the Distribution
Wires Business (as per the prevalent CERC Regulations) and a rate of 16% for the Retail Supply Business. The
equity component has been determined in accordance with capital structure as discussed above in Section 4.11:
Capital Structure of this Order.

The RoE has been calculated on the average of opening and closing of equity during FY 2020-21 at the rate of
16% on post-tax basis for Retail Supply Business and 15.50% on post-tax basis for wires business, with the
opening equity considered equivalent to the closing equity of FY 2019-20 as approved in the True-up chapter of
this order. The following table provides the Return on Equity approved in ARR order, Petitioner’s submission
and approved for the FY 2020-21 by the Commission.

Table 62: Return on Equity approved by Commission for FY 2020-21


S. Approved in Petitioner’s Now Approved
Particulars
No ARR order Submission by Commission
1 Opening Equity 101.79 140.05 104.42
Additions on account of new
2 54.81 54.81 47.61
capitalization
3 Closing Equity 156.60 194.86 152.03
4 Average Equity 129.19 167.46 128.23
5 Equity for wire business (90%) 116.27 150.71 115.40
6 Equity for Retail Supply Business (10%) 12.92 16.75 12.82
7 Return on Equity for Wire Business (%) 15.50% 15.50% 15.50%
Return on Equity for Retail Supply
8 16.00% 16.00% 16.00%
Business (%)
9 Return on Equity for Wire Business 18.02 23.36 17.89
Return on Equity for Retail Supply
10 2.07 2.68 2.05
Business
11 Return on Equity 20.09 26.04 19.94

Return on Equity approved by the Commission is lower in comparison to as claimed by the petitioner because
the Commission has considered less opening equity than that of Petitioner. In FY 2019-20 the petitioner has
claimed wrong opening equity (i.e. average of closing equity of FY 2018-19 instead of closing equity of FY 2018-
19) due to which the opening equity for subsequent years considered by Petitioner is higher in comparison to
that approved by the Commission.

Accordingly, the Commission approves the Return on Equity of INR 19.94 Crore in the APR of
FY 2020-21.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 91
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Interest on Security Deposits


Petitioner’s Submission

The Petitioner has submitted INR 4.20 Crore as revised estimates for interest on consumer security against INR
2.70 Crore approved by the Commission in the ARR Order.

Commission’s Analysis:

Regulation 28.11 of the JERC MYT Regulations, 2018 stipulates the following:

“28.11 Interest shall be allowed on the amount held as security deposit held in cash from Retail Consumers at
the Bank Rate as on 1st April of the Financial Year in which the Petition is filed:

Provided that at the time of truing-up, the interest on the amount of security deposit for the Year shall be
considered on the basis of the actual interest paid by the Licensee during the Year, subject to prudence check
by the Commission.”

The Petitioner has not submitted any data regarding the Opening, addition & closing in the consumer security
deposits. So, the Commission approves the interest on security deposit as proposed by the petitioner. The same
shall be trued-up on the actual basis. The table below provides approved consumer security deposits for the
year FY 2020-21:

Table 63: Interest on Security Deposits approved by Commission for FY 2020-21 (INR Crore)
Approved in ARR Petitioner's Now Approved
S. No Particulars
Order Submission by Commission
1 Interest on Security Deposit 2.70 4.20 4.20

The Commission approves Interest on Security Deposit as INR 4.20 Crore in the APR of FY
2020-21.

Interest on Working Capital


Petitioner’s submission

The interest on working capital has been calculated based on the normative principles in the JERC (Multi Year
Tariff) Regulations, 2018.

The working capital requirement for FY 2020-21 has been computed considering the following parameters:

(a) Receivables for two months


(b) O&M Expenses for one month.
(c) Less consumer security deposit but excluding Bank Guarantee/Fixed Deposit
(d) Maintenance Spares at 40% of R&M for one Month

The Interest on Working Capital is computed considering interest rate of 10.55% (1-year SBI MCLR plus 200
basis points) in line with the MYT Regulations, 2018.

Table 64: Interest on Working Capital submitted by Petitioner for FY 2020-21


Approved in ARR Petitioner's
S. No Particulars
Order Submission
1 O&M expense for one month 2.73 3.65
2 Maintenance spares at 40% of R&M for one 0.30 0.75

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 92
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Approved in ARR Petitioner's


S. No Particulars
Order Submission
month
3 Receivables for 2 months 598.28 484.55
4 Total 601.31 488.95
Less consumer security deposit but excluding
5 53.08 60.63
Bank Guarantee/Fixed Deposit Receipt
Net Working Capital required after deduction of
6 548.23 428.32
Security Deposit
7 Interest on Working Capital 57.84 41.76

Commission’s Analysis:

The Regulation 52 of the MYT Regulations, 2018 stipulates the following:

“52. Norms of Working Capital for Retail Supply Business

52.1 The Distribution Licensee shall be allowed interest on the estimated level of working capital for the Retail
Supply Business for the Financial Year, computed as follows:

(a) O&M Expenses for one (1) month; plus

(b) Maintenance spares at 40% of repair and maintenance expenses for one (1) month; plus

(c) Receivables equivalent to two (2) months of the expected revenue from charges for use of distribution
wires at the prevailing tariff;

Less:

(d) Amount, if any, held as security deposits under clause (b) of sub-section (1) of Section 47 of the Act from
distribution system users except the security deposits held in the form of Bank Guarantees:

Provided, that at the time of truing up for any Year, the working capital requirement shall be re-calculated on
the basis of the values of components of working capital approved by the Commission in the truing up.”

Further, Regulation 31.3 and 31.4 of the MYT Regulation, 2018 stipulates the following:

“31 Interest on Working Capital

…………

31.3 The interest on working capital shall be a payable on normative basis notwithstanding that the Licensee
has not taken working capital loan from any outside agency or has exceeded the working capital loan based
on the normative figures.

31.4 The rate of interest on working capital shall be equal one (1) Year State Bank of India (SBI) MCLR / any
replacement thereof as notified by RBI for the time being in effect applicable for one (1) Year period, as may
be applicable as on 1st April of the Financial Year in which the Petition is filed plus 200 basis points.”

In accordance with the MYT Regulation, 2018, the Commission has computed the Interest on Working Capital
for FY 2020-21. The rate of interest on working capital is considered as 1-year SBI MCLR rate as on April 1,
2020 plus 200 basis points (7.75%+2% = 9.75%).

The following table provides the interest on working capital approved by the Commission in the ARR Order,
Petitioner’s submission and now approved by the Commission.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 93
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Table 65: Interest on Working Capital approved by Commission for FY 2020-21 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 O&M expense for one month 2.73 3.65 2.53
Maintenance spares at 40% of R&M
2 0.30 0.75 0.33
for one month
Receivables equivalent to two (2)
3 months of the expected revenue 598.28 484.55 490.86
requirement
4 Total Working Capital 601.31 488.95 493.71
Less consumer security deposit but
5 excluding Bank Guarantee/Fixed 53.08 60.63 60.63
Deposit Receipt
Net Working Capital required after
6 548.23 428.32 433.08
deduction of Security Deposit
7 Interest (%) 10.55% 9.75% 9.75%
8 Interest on Working Capital 57.84 41.76 42.23

The Interest on WC approved by the Commission is higher as compared to Petitioner’s claim due to higher
revenue (receivables) approved by the Commission for FY 2020-21. The same shall be accounted for as per
actuals in the true-up of FY 2020-21.

Accordingly, the Commission approves the Interest on Working Capital as INR 42.23 Crore in
the APR of FY 2020-21.

Income Tax
Petitioner’s submission

The Petitioner has proposed INR 26.21 Cr towards Income tax for FY 2020-21.

Commission’s Analysis:

Regulation 32 of the MYT Regulations, 2018 provides for allowance of provisional Income Tax based on the
actual income tax paid in previous year, if any, as per the latest audited accounts available. The Commission
directed the petitioner to submit actual income tax payment receipt, if any. The Petitioner submitted bank’s
taxpayer’s counter foil (advance tax payment) amounting to INR 15.00 Cr. Accordingly, for FY 2020-21, actual
paid income tax has been considered at this stage which will be trued up based on actuals subject to prudence
check.

Table 66: Income tax approved by Commission for FY 2020-21 (INR Crore)
Approved in ARR Petitioner's Now Approved
S. No Particulars
Order Submission by Commission
1 Income Tax 0.00 26.21 15.00

The Commission approves INR 15.00 Cr for actual income tax paid in the APR of FY 2020-21.

Provision for Bad & Doubtful Debts


Petitioner’s submission

The Petitioner has not proposed any provision for bad and doubtful debts for the FY 2020-21.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 94
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

As per the petitioner submission, the Commission has not considered any provision for Bad & Doubtful Debts.
The same shall be accounted for as per actuals in the true-up of FY 2020-21.

Non-Tariff Income
Petitioner’s submission
The non-tariff income for FY 2020-21 has been estimated by considering elements like sale of scrap, reactive
income, STOA application fees, supervision charges etc. However, one-time income like provision written back
has not been considered to estimate the non-tariff income for FY 2019-20 in accordance to MYT Regulations,
2018. Accordingly, a revised estimate of INR 8.22 Crore has been submitted for FY 2020-21.
Commission’s Analysis:

The Regulation 64 of the MYT Regulations, 2018 stipulates the following:

“64. Non-Tariff Income

64.1 The amount of Non-Tariff Income relating to the retail supply of electricity as approved by the
Commission shall be deducted from the Aggregate Revenue Requirement in calculating the tariff for retail
supply of electricity by the Distribution Licensee:

Provided that the Distribution Licensee shall submit full details of its forecast of Non-Tariff Income to the
Commission along with its application for determination of tariff.

64.2 The Non-Tariff Income shall inter-alia include:

(a) Income from rent of land or buildings;

(b) Income from sale of scrap;

(c) Income from statutory investments;

(d) Interest on advances to suppliers/contractors;

(e) Rental from staff quarters;

(f) Rental from contractors;

(g) Income from hire charges from contactors and others;

(h) Income from advertisements, etc.;

(i) Meter/metering equipment/service line rentals;

(j) Service charges;

(k) Consumer charges;

(l) Recovery for theft and pilferage of energy;

(m) Rebate availed on account of timely payment of bills;

(n) Miscellaneous receipts;

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 95
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

(o) Deferred Income from grant, subsidy, etc., as per Annual Accounts;

(p) Prior period income, etc.:

Provided that the interest/dividend earned from investments made out of Return on Equity corresponding to
the Retail Supply Business of the Distribution Licensee shall not be included in Non-Tariff Income:

Provided further that any income earned by a Distribution Licensee by sale of power to other Distribution
Licensees or to Consumers as per Section 49 of the Act using the existing power purchase agreements or bulk
supply capacity allocated to the Distribution Licensee’s Area of Supply shall be reduced from the Aggregate
Revenue Requirement of the Distribution Licensee for the purpose of determination of tariff. Such reduction
shall be carried out in accordance with Joint Electricity Regulatory Commission for the State of Goa and
Union Territories (Connectivity and Open Access in Intra-State Transmission and Distribution) Regulations,
2017, as amended from time to time.”

Further, the Regulation 34.2 of the MYT Regulations, 2018 stipulates the following:

“34.2 The delayed payment charge earned by the Transmission Licensee or the Distribution Licensee shall not
be considered under its Non-Tariff Income.”

For the APR of FY 2020-21, the Commission has considered escalation of 5% over the approved Non-Tariff
Income for FY 2019-20 (INR 11.48 Crore). The same shall be considered at actuals at the time of truing up of FY
2020-21.
The NTI approved in the ARR Order, the Petitioner’s submission and now approved by the Commission is
shown in the table below:

Table 67: Non-Tariff Income approved by Commission for FY 2020-21 (INR Crore)
Approved in ARR Petitioner's Now Approved
S. No Particulars
Order Submission by Commission
1 Non-Tariff Income 14.88 8.22 12.06

The Commission now approves Non-Tariff Income of INR 12.06 Crore in the APR for FY 2020-
21.

Aggregate Revenue Requirement (ARR)


Petitioner’s submission

Based on the expenses as detailed above, the net Aggregate Revenue Requirement of INR 2,861.15 Crore is
submitted after adjusting the Non -Tariff Income for FY 2020-21.

Commission’s Analysis

On the basis of the detailed analysis of the cost parameters of the ARR, the revenue requirements in the APR of
FY 2020-21 are approved as follows:

Table 68: Aggregate Revenue Requirement approved by the Commission for FY 2020-21 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
ARR Order Submission by Commission
1 Power Purchase Cost 3,340.99 2,700.54 2628.41
2 Operation & Maintenance Expenses 31.28 43.75 30.32
3 Depreciation 19.19 19.93 18.44
4 Interest and Finance charges 6.08 6.95 5.81
5 Interest on Working Capital 57.84 41.76 42.23

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 96
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Approved in Petitioner's Now Approved


S. No Particulars
ARR Order Submission by Commission
6 Interest on Security Deposit 2.70 4.20 4.20
7 Return on Equity 20.09 26.04 19.94
8 Income Tax 0.00 26.21 15.00
9 Total Revenue Requirement 3,478.17 2,869.37 2,764.35
10 Less: Non-Tariff Income 14.88 8.22 12.06
11 Net Revenue Requirement 3,463.28 2,861.15 2,752.29

The Commission approves the net ARR of INR 2,752.29 Crore in the APR of FY 2020-21.

Revenue at existing Retail Tariff


Petitioner’s submission

The Petitioner in its Petition submitted that the total revenue of INR 2,907.33 Crore, which includes INR
2,843.02 Crore from sale of power at existing tariff, INR 46.09 Crore from FPPCA and INR 18.22 Crore from
revenue from sale of surplus power. The estimated revenue for FY 20-21 is based on the six months actual
revenue at the exiting tariff. The revenue for remaining six months of FY 20-21 has been computed based on the
retail tariff notified by the Commission in the Tariff Order for the FY 2020-21 dated 18th May, 2020. The total
revenue estimated for the FY 2020-21 includes the actual FPPCA billed during the first six months.

Commission’s Analysis

The Commission through a deficiency note directed the Petitioner to provide actual revenue from sale of power
for months of April to December 2020 of FY 2020-21, which was accordingly submitted by the Petitioner. The
category wise/ sub-category wise and slab-wise revenue at existing retail tariff is calculated as per the tariff
rates applicable for FY 2020-21. The revenue from demand charges and the energy charges have been projected
for each category/ sub-category and slab.

The revenue from category/ sub-category/ slab-wise revenue as computed by the Commission for FY 2020-21
have been shown in the following table:

Table 69: Revenue at existing tariff computed by Commission for FY 2020-21


Fixed Energy
Total
Charges charges ABR
S. No. Category (INR
(INR (INR (INR/unit)
Crore)
Crore) Crore)
1 DOMESTIC 0.99 35.41 36.41 2.49
(i) 0-50 units 0.11 4.30 4.41 1.50
(ii) 51-200 units 0.27 11.26 11.52 2.21
(iii) 201-400 units 0.13 6.88 7.01 2.75
(iv) 401 and above 0.14 12.98 13.12 3.37
(v) Low Income Group 0.34 - 0.34

COMMERCIAL/Non-
2 0.18 15.93 16.12 4.15
Domestic
(i) 0-100 units 0.11 2.02 2.13 3.33
(ii) 101 Units and Above 0.07 13.92 13.99 4.31

3 LT INDUSTRIAL
LTP Motive Power (For All
(i) 14.85 85.24 100.09 5.35
Units)
Up to 20 HP 0.10 2.15 2.25 4.57

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 97
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Fixed Energy
Total
Charges charges ABR
S. No. Category (INR
(INR (INR (INR/unit)
Crore)
Crore) Crore)
Above 20 HP 14.75 83.09 97.84 5.38
LT Public Water Works (For
(ii) 0.61 2.44 3.05 5.90
all units)
Up to 20 HP 0.01 2.44 2.46 4.74
Above 20 HP 0.60 0.00 0.60 0.00

4 HT/EHT 606.76 2105.72 2712.48 5.71


(i) 11 kV 280.27 919.79 1200.05 5.82
(iii) 66 kV 153.71 601.01 754.71 5.54
(iv) 220 kV 172.79 584.93 757.72 5.71

AGRICULTURE AND
5 0.00 0.55 0.55 0.89
POULTRY
(i) For sanctioned load upto 10 HP 0.00 0.34 0.34 0.79
Beyond 10 HP and up to 99 HP
(ii) 0.00 0.21 0.21 1.13
sanctioned load

6 PUBLIC LIGHTING 0.00 1.37 1.37 4.20


(i) For all units 1.37 1.37 4.20

7 HOARDINGS/SIGNBOARDS 0.00 0.00 0.00


(i) For all units 0.00 0.00

8 TEMPORARY* 0.00 2.71 2.71 8.20


Total 623.40 2249.38 2872.78 5.59
*Tariff is 1.5 Times the ABR of Revenue at existing tariff for FY 2020-21

The Revenue from retail sales approved by the Commission is higher as compared to Petitioner’s claim firstly
due to change in sales mix, although the sales considered by the Commission is marginally less but in individual
category the sales is higher for categories having higher tariff rates. Secondly, the petitioner has considered the
wrong Connected Load numbers in HT Industry category for the calculation of revenue.

The Commission has determined revenue from sale of power at existing tariff as INR 2,872.78
Crore in the APR of FY 2020-21.

FPPCA Computation
Petitioner’s submission

The Petitioner has submitted INR 46.09 Crore as revised estimates for FPPCA against Nil approved by the
Commission in the ARR Order.

Commission’s Analysis

The Commission has computed the revenue from FPPCA for FY 2020-21 considering FPPCA rate approved by
the Commission for first quarter of FY 2020-21 and billed in third quarter of FY 2020-21 respectively, the actual
quarterly sales for the corresponding quarters and the K factor approved in the MYT Order. Further due to
unavailability of data the Commission has not considered FPPCA for any other quarter of the FY 2020-21.

FPPCA rates approved by the Commission for FY 2020-21 are as given in following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 98
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

Table 70: FPPCA Rates approved by Commission for FY 2020-21


S. No FY 2020-21 FPPCA Rates (INR/kWh)
1 Quarter 1 (April to June 2020) 0.53

The FPPCA Computation is provided in the table shown below:

Table 71: Computation of Revenue from FPPCA for FY 2020-21


Total Revenue from
Particulars Sales for Q3 (MUs) k-Factor
FPPCA (INR Crore)
Domestic 33.85 0.47 0.95
Commercial
8.79 0.79 0.32
LT Industrial (Motive Power) 59.33 0.98 2.40
LT Public Water Works 1.26 1.02 0.07
HT/EHT 1489.51 1.02 68.56
Agriculture & Poultry 1.18 0.17 0.00
Public Lighting 0.66 0.79 0.02
Temp. Supply 0.92 1.33 0.07
Total 1,595.50 72.39

The following table provides revenue from FPPCA as per Petitioner’s submission and as approved by the
Commission:

Table 72: Revenue from FPPCA allowed by the Commission for FY 2020-21 (INR Crore)
Petitioner's Now Approved by
S. No Particulars
Submission Commission
1 FPPCA 46.09 72.39

The Commission has determined revenue from FPPCA as INR 72.39 Crore in the APR of FY
2020-21.

Standalone Revenue Gap/Surplus


Petitioner’s submission

Based on the ARR and the revenue from retail tariff, a standalone revenue surplus of INR 46.18 Crore is
observed the APR for FY 2020-21.

Commission Analysis

The Standalone Revenue Gap/ (Surplus) approved in the ARR Order, as submitted by the Petitioner and now
approved by the Commission is arrived at and approved as follows:

Table 73: Standalone Revenue Gap/ (Surplus) at existing tariff for FY 2020-21 (INR Crore)
S. Approved in Petitioner’s Now Approved by
Particulars
No ARR Order submission Commission
1 Annual Revenue Requirement 3,463.28 2,861.15 2752.29
Revenue from sale of power at
2 3,589.67 2,843.02 2,872.78
existing tariff
3 FPPCA 0.00 46.09 72.39
4 Revenue from sale of surplus power 0.00 18.22 0.00*

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 99
DNH Power Distribution Corporation Limited (DNHPDCL)
Annual Performance Review for FY 2020-21 Joint Electricity Regulatory Commission (JERC)

S. Approved in Petitioner’s Now Approved by


Particulars
No ARR Order submission Commission
5 Total Revenue 3,589.67 2,907.33 2,945.17
Revenue Gap/(Surplus) (126.39) (46.18) (192.88)

*As provided in Table 43 of section 4.6 Energy Balance, as per the projections made by the Commission, the
Energy Requirement is more than the Energy available from firm and non-firm sources. The remaining
energy will be procured from open market/exchanges and no surplus power is available for sale in Open
Market. So, the Commission did not consider any revenue from Sale of surplus power unlike the Petitioner.

The standalone surplus at existing retail tariff is INR 192.88 Crore in the APR of FY 2020-21.
This estimated surplus is carried over to the next year and has been considered while
determining the tariff for FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 100
DNH Power Distribution Corporation Limited (DNHPDCL)
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

5. Chapter 5: Determination of
Aggregate Revenue Requirement for
FY 2021-22

Background
The ARR for the FY 2021-22 was approved in the MYT Order issued for the 2nd Control Period (the FY 2019-20
to the FY 2021-22 on 2oth May, 2019). In this Chapter the Commission determines the revised Aggregate
Revenue Requirement (ARR) for FY 2021-22 based on truing up for FY 2019-20 and APR for FY 2020-21 in
accordance with the provisions of MYT Regulations, 2018.

Approach for determination of ARR for the FY 2021-22


This Chapter analyses the individual elements constituting the Aggregate Revenue Requirement for the FY
2021-22, approved in the MYT Order dated 20th May, 2019 and re-computes the same considering the actual
information available of various parameters for the FY 2019-20 as per the audited accounts and the provisional
information available for first 9 months of the FY 2020-21. The revised ARR and revenue at existing tariff is
determined for the FY 2021-22 to arrive at the revised revenue gap/surplus for the year.

Projection of Number of consumers, Connected Load and


Energy Sales
Petitioner’s Submission

The Petitioner submitted that the energy sales is projected for FY 2021-22 based on the historical trends
observed in the last six years (the FY 2014-15 to the FY 2019-20)

The Petitioner further submitted that the factors affecting the actual consumption of electricity are numerous
and often beyond the control of the utility including factors such as Government Policy, economic climate,
weather conditions and force majeure events like natural disasters, etc. The Petitioner, therefore for projecting
the category-wise consumption for the FY 2021-22 has considered the past growth trends in each of the
consumer category including growth trend in number of consumers and connected load.

The Petitioner submitted that the number of consumers and connected load growth has been considered same
as number of consumers and connected load approved by the Commission in its Business Plan Order for 2 nd
Control Period.

Commission’s Analysis

The Commission sought the details regarding basis and assumptions for projecting category-wise energy sales.
In reply, the Petitioner submitted that for projecting the category wise sales for the FY 2021-22, it has
considered the growth in the sales for the preceding years and has also considered CAGR. Based on the growth
witnessed in different categories the sales for the FY 2021-22 have been projected.

Since in APR of FY 2020-21, the sales projected by the Petitioner (5,153.96 MUs) and sales approved by the
Commission (5,142.89 MU) are almost same, hence for FY 2021-22 the Commission considered the sales same
as projected by petitioner which is 6,540.77 MU.
The category-wise number of consumers and connected load were projected in Business Plan Order dated 5th
November 2018 that were based on some detailed analysis. The Commission at this stage has not revised the

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 101
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

projections for number of consumers and connected load and has considered same as approved in Business
Plan Order.

Table 74: Number of Consumers approved by the Commission for FY 2021-22


Approved in MYT Petitioner’s Now Approved by
Category
Order Submission Commission
Domestic 54,654 54,654 54,654
LIG/Kutir Jyoti 15,736 15,736 15,736
Commercial /Non-Domestic 8,516 8,516 8,516
Agriculture 1,538 1,538 1,538
LT Industry 2,117 2,117 2,117
HT/EHT Industry 968 968 968
Public Lighting 480 480 480
Public Water Works 563 563 563
Temp. Supply 379 379 379
Total 84,952 84,951 84,952

Table 75: Connected Load approved by the Commission for FY 2021-22 (kW)
Approved in MYT Petitioner’s Now Approved by
Category
Order Submission Commission
Domestic 113,470 113,470 113,470
LIG/Kutir Jyoti 1,801 1,801 1,801
Commercial /Non-Domestic 30,371 30,371 30,371
Agriculture 6,260 6,260 6,260
LT Industry 125,566 125,566 125,566
HT/EHT Industry 1,218,170 1,218,170 1,218,170
Public Lighting 3,281 3,281 3,281
Public Water Works 4,207 4,207 4,207
Temp. Supply 2,537 2,537 2,537
Total 1,505,663 1,505,663 1,505,663

The revised energy sales for each category are tabulated as follows:

Table 76: Energy Sales projected by the Commission for FY 2021-22 (MUs)
Approved in MYT Petitioner’s Now Approved by
Category
Order Submission Commission
Domestic 158.29 167.74 167.74
Commercial /Non-Domestic 38.31 38.89 38.89
Agriculture 8.25 5.46 5.46
LT Industry 223.82 227.55 227.55
HT/EHT Industry 6,273.63 6,088.87 6,088.87
Public Lighting 9.1 3.22 3.22
Public Water Works 10.95 5.26 5.26
Temp. Supply 3.39 3.79 3.79
Total 6,725.73 6,540.77 6,540.77

The Commission approves energy sales of 6,540.77 MUs in the ARR of the FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 102
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Inter-State Transmission Loss


Petitioner’s submission

The same Inter-State Transmission Loss of 3.66% is considered as approved in the MYT Order.

Commission’s Analysis

The Commission has decided to continue with the loss trajectory as specified in the MYT Order for the FY 2021-
22

The table below provides the Inter-State Transmission Loss approved by the Commission:

Table 77: Inter-State transmission loss as approved by the Commission for FY 2021-22 (%)
Approved in Petitioner’s Now Approved by
S. No Particulars
MYT Order Submission Commission
1 Inter-State transmission loss 3.66% 3.66% 3.66%

The Commission approves an Inter-State Transmission Loss of 3.66 % in the ARR of the FY
2021-22.

Distribution Loss
Petitioner’s submission

The Petitioner has submitted that it has achieved distribution loss level of 3.45 % for the FY 2019-20. It further
submitted that reduction in distribution loss involves significant amount of capital expenditure and that it will
endeavor to bring the distribution loss level further down in the subsequent years. The petitioner further
submitted that the Commission had set a T&D loss level target of 4.10% for the FY 2021-22 in the Tariff Order
dated 20th May, 2019. The petitioner has kept the T&D losses at the same level as approved by the Commission
for FY 21-22.

Accordingly, Petitioner has proposed to keep the Distribution losses same as Commission’s approved
distribution losses for FY 2021-22, i.e., 4.10 %.

Commission’s Analysis

Regulation 12.2 (c) of the JERC, MYT Regulations, 2018, provides as follows:

“12.2 For the purpose of these Regulations, the term “controllable factors” for a Transmission or Distribution
Licensee shall comprise of the factors which were within the control of the Licensee, shall inter-alia include:

…..

d) Variations in technical and commercial losses of Distribution Licensee;

…….”

As per Regulation 12.2 (c) of the JERC, MYT Regulations, 2018, distribution loss is a controllable factor, so the
Commission now approves the same distribution losses as approved in the MYT Order for FY 2021-22. The
Petitioner shall be allowed an incentive/disincentive in the true-up Order for FY 2021-22 considering the actual
distribution loss achieved by the Petitioner in the year. Hence, for FY 2021-22 the Commission retains the
distribution loss level of 4.10% as approved in the MYT Order dated May 20, 2019.

The following table provides Distribution Loss approved by the Commission:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 103
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 78: Distribution loss as approved by the Commission for FY 2021-22 (%)
Approved in Petitioner’s Now Approved by
S. No Particulars
MYT Order Submission Commission
1 Distribution loss 4.10% 4.10% 4.10%

The Commission approves the Distribution loss of 4.10 % in the ARR of FY 2021-22.

Energy Balance
Petitioner’s submission

The Petitioner has submitted the energy balance for FY 2021-22 as shown in following table:

Table 79: Energy Balance submitted by Petitioner for FY 2021-22 (MU)


Particulars Value
Sales 6540.77
Open Access Sales 0.00
Less: Energy Savings 0.00
Total Sales 6540.77
Add: Losses 279.64
T&D Losses 4.10%
Energy Required at Periphery 6820.41
Add: Sales to common pool consumer 0.63
Add: Sales through IEX 0.00
Less: Own Generation 6.18
Total energy requirement at state periphery 6814.86
Less: Energy Purchased through UI at Periphery 0.00
Less: Energy Purchased through Renewable Sources 175.20
Less: Open Access Purchase 0.00
Less: Purchase from Power Exchange 927.00
Total Energy Required at Periphery 5712.66
Transmission loss 217.03
Transmission loss (%) 3.66%
Total Energy to be purchased 5929.69
Total Energy requirement from tied up sources & UI at generator end 7038.07
Total Energy requirement in UT including Open Access 7038.07

Commission’s Analysis

Based on the revised estimates of energy sales and Power purchase quantum, the Commission approves the
following energy balance for FY 2021-22:
Table 80: Energy Balance approved by Commission for FY 2021-22 (MU)
Approved
Sr. Petitioner’s Now Approved
Particulars Formulae in ARR
No. Submission by Commission
Order
A Sales 6,725.74 6,540.77 6540.77
B Open Access Sales 0 0 0

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 104
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Approved
Sr. Petitioner’s Now Approved
Particulars Formulae in ARR
No. Submission by Commission
Order
C Less: Energy Savings 0 0 0
D Total Sales D=A+B-C 6,725.74 6,540.77 6540.77

T&D Losses
E in % 4.10% 4.10% 4.10%
F in MU F=G-D 287.54 279.64 279.64
Energy Required at
G G=D/(1-E) 7,013.28 6,820.41 6820.41
Periphery
Add: Sales to common pool
0 0.63
H consumer 0
I Add: Sales through IEX 0 0 0
J Less: Own Generation 5.23 6.18 6.18
Total energy requirement at
K=G+H+I-J 7,008.05 6,814.86 6814.23
K state periphery
Less: Energy Purchased
0 0
L through UI at Periphery 0.00
Less: Energy Purchased
1927.2 175.2 175.20
M through Renewable Sources
N Less: Open Access Purchase 0.00 0.00 0.00
Less: Purchase from Power
0.00 927.00 927.00
O Exchange
Total Energy Required at
P=K-L-M-N-O 5,080.85 5,712.66 5712.03
P Periphery
R Transmission loss (%) 3.66% 3.66% 3.66%
Q Transmission loss Q=S-P 193.02 217.03 217.00
Total requirement from
S Tied-up sources at S=P/(1-R) 5,273.88 5,929.69 5,929.03
generator end (MU)
Total availability from tied
T up sources at generator 5,185.22 - 5,920.42
end (MU)
U Deficit/(surplus) U=S-T 88.66 - 8.61

The Commission has considered power purchase of 927 MUs from open market sources as per petitioner
submission. Further the Commission has approved an additional power purchase of 8.61 MUs from open
market to meet the deficit as approved in table above. Accordingly, the Commission has approved 935.61 MUs
from Open Market/Power Exchange. The Commission has considered a price of INR 3.02/ kWh for such power,
considering the escalation of 5% over the actual per unit price of power purchased by the Petitioner in first nine
months of FY 2020-21 from open market sources (Energy Exchange/ Bilateral). This cost has been included in
the Power Purchase cost allowed by the Commission.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 105
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Power Purchase Quantum & Cost

5.7.1. Availability of power


Petitioner’s Submission

Petitioner has firm and infirm allocations in Central Sector Generating Stations of NTPC, Nuclear Power
Corporation of India Ltd (NPCIL), NTPC Sail Power Company Ltd (NSPCL), etc.

The power availability has been estimated based on the revised allocation specified in the notification No.
WRPC/Comml-I/6/Alloc/2020 dated 15/10/2020 of Western Regional Power Committee.

Table 81: Energy Allocation as submitted by the Petitioner for FY 2021-22 (MW)
Weighted average Weighted Average Weighted average
Name of the plant Infirm allocation Firm allocation total allocation
KSTPP 51.20 0.00 51.20
KSTPS -3 19.68 2.20 21.88
VSTPP-I 37.03 5.00 42.03
VSTPP-II 27.97 4.00 31.97
VSTPP- III 27.97 6.00 33.97
VSTPP- IV 39.36 5.55 44.91
KAWAS 56.18 25.00 81.18
GGPP 56.74 2.00 58.74
Sipat – I 77.93 9.00 86.93
Sipat – II 26.56 4.00 30.56
KHSTPP – II 3.50 0.00 3.50
Mauda I (MSTPS) 39.36 5.55 44.91
VSTPP-V 19.68 5.55 25.23
Mauda II 51.95 8.60 60.55
Solapur 51.95 21.57 73.52
Gadarwara 31.49 10.42 41.91
LARA 31.20 5.23 36.43
Kharagaon 51.95 16.83 68.78
NPCIL – KAPS 10.36 2.00 12.36
NPCIL - TAPS 3&4 35.03 7.00 42.03
Total 747.07 145.50 892.57
NSPCL Bhilai 100.00 100.00

The availability of power from various sources has been considered as per the following methodology:

• It is expected that Petitioner will not be getting any power from Ratnagiri during the FY 2021-22 and
therefore no power purchase from the plant has been considered.

• Power purchase quantum from the NTPC stations for the FY 2021-22 has been calculated based on the
installed capacity of each plant and by applying the PLF approved by the Commission vide Order for
the Business Plan dated 5th November, 2018.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 106
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

• Auxiliary consumption of 7.75% and 2.5% has been considered for coal and gas based generating
stations, respectively.

• Additionally, the DNHPDCL was procuring power from EMCO Energy Limited (GMR) power plant in
Maharashtra. DNHPDCL had signed a seven year PPA with EMCO Energy Limited (GMR) and the
same came to an end on June, 2020. Hence, power purchase from EMCO has not been considered for
the FY 2021-22.

• DNHPDCL will be getting 50 MW of wind energy from SECI from FY 2021-22 for which the agreement
has already been signed. Further, the DNHPDCL has already installed 4.585 MW of solar plants in its
territory for generation of solar energy out of which 4.1 MW is ground mounted and 485 KW is solar
rooftop.

The following table depicts the source wise power purchase quantum for the FY 2021-22:

Table 82: Station wise power purchase submitted by Petitioner for FY 2021-22 (MUs)
Power Purchase
Source
Quantum
NTPC Stations
KSTPP 1&2 368.22
KSTPS 3 159.12
VSTPP-I 292.12
VSTPP-II 219.61
VSTPP- III 236.09
VSTPP- IV 312.08
KAWAS 277.35
JGPP 210.72
Sipat-I 632.20
Sipat-II 222.27
MSTPL 1 174.18
VSTPS-V 175.33
Mauda 2 234.87
Solapur 356.47
LARA 246.81
Gadarwara 283.95
Kharagaon 466.04
KHSTPP-II 22.06
Subtotal 4,889.52
NSPCL – Bhilai 703.06
NSPCL – Rourkela

NPCIL
KAPS 70.53
TAPS 3&4 266.59
Subtotal 337.12
Total Firm 5,929.69
Power purchase from Other Sources
Indian E. Exchange/Bilateral 927.00
UI 0.00
Solar 6.18
Non Solar 175.20
Solar REC 0.00

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 107
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Power Purchase
Source
Quantum
Non Solar REC 0.00
Solar (SECI) 0.00
Wind (SECI) 0.00
Subtotal 1,108.38
Misc. Arrears
Power Purchase Cost 7,038.00
External Losses 0.00
Availability at ED-DNH Periphery 7,038.07

Commission’s Analysis

The approach followed for projecting the availability from various generating stations is as follows:

Availability of power from NTPC & NTPC-SAIL Bhilai:

• The power purchase quantum from NTPC stations has been estimated based on the average of quantum
of energy availed during last 3 financial years (FY 2018-19, FY 2019-20 & FY 2020-21).

• For NTPC VSTPP-I, Kawas, JGPP, Sipat-II, Solapur, Lara, Gadarwara & Bhilai power plant, energy
availability has been considered same as submitted by the petitioner, due to irregular scheduling of
power in past years or due to higher purchase projected by the petitioner in FY 2021-22.

Availability from NPCIL plants:

• For nuclear plant KAPS energy availability is considered same as submitted by the petitioner, due to
irregular scheduling of power in last three financial years (FY 2018-19, FY 2019-20 & FY 2020-21).
• The power purchase quantum of TAPS has been estimated based on the average of quantum of energy
availed during last 3 years (FY 2018-19, FY 2019-20 & FY 2020-21).

Availability of power from Open Market

• The estimated energy deficit for the FY 2021-22 discussed in section of “Energy Balance” has been
assumed to be procured from open market.

• No power has been allowed under UI for the FY 2021-22.

5.7.2. Power Purchase Cost


Petitioner’s Submission

The cost of purchase from the central generating stations for FY 2021-22 has been estimated based on the
following assumptions:
• Fixed cost for the FY 2021-22 has been projected by considering an escalation of 5% on the fixed cost
estimated for various stations for the FY 2020-21.
• Variable cost for each NTPC generating stations for the FY 2021-22 has been projected by giving an
escalation of 5% on the actual variable cost incurred during the first six months of FY 2020-21 for
various stations.
• For nuclear plants, i.e., KAPS and TAPS single part tariff, an escalation of 5% has been given on the
actual average variable cost per unit incurred for the first six months of FY 2020-21 for projecting the
cost for the FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 108
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

• For NTPC-SAIL Bhilai unit 1 & 2, the fixed has been projected by giving an escalation of 5% on fixed
cost estimated for the FY 2020-21 and for projecting the variable cost an escalation of 5% has been
given on the actual average variable cost per unit incurred for the first six months of FY 2020-21.
• For power purchase from renewable energy sources, for the FY 2021-22, the DNHPDCL has outsourced
the maintenance cost of the solar plants to BHEL. For the purchase of 50 MW wind power a rate of Rs.
2.59 per unit has been considered for the FY 2021-22.
The Total Power Purchase cost from various sources for the FY 2021-22 is summarized in the table below:

Table 83: Power Purchase quantum (MU) and Cost (INR Crore) submitted by Petitioner for FY 2021-22
All Per
Units Fixed Variable Other
Source Charges Unit
Purchased Charges Charges Charges
Total Cost
NTPC Stations
KSTPP 1&2 368.22 22.93 58.79 0.00 81.72 2.22
KSTPS 3 159.12 21.10 25.20 0.00 46.31 2.91
VSTPP-I 292.12 20.82 53.98 0.00 74.81 2.56
VSTPP-II 219.61 13.88 39.53 0.00 53.40 2.43
VSTPP- III 236.09 22.89 42.58 0.00 65.47 2.77
VSTPP- IV 312.08 48.06 54.56 0.00 102.62 3.29
KAWAS 277.35 50.39 58.62 0.00 109.01 3.93
JGPP 210.72 46.60 46.36 0.00 92.96 4.41
Sipat-I 632.20 76.35 105.97 0.00 182.32 2.88
Sipat-II 222.27 24.61 38.52 0.00 63.13 2.84
MSTPL 1 174.18 58.65 52.79 0.00 111.44 6.40
VSTPS-V 175.33 27.82 31.88 0.00 59.70 3.41
Mauda 2 234.87 62.58 72.23 0.00 134.81 5.74
Solapur 356.47 88.91 107.47 0.00 196.38 5.51
LARA 246.81 48.40 53.43 0.00 101.83 4.13
Gadarwara 283.95 58.41 75.52 0.00 133.94 4.72
BARH 0.00 0.00 0.00 0.00 0.00 -
Dhuwaran 466.04 101.14 136.39 0.00 237.52 5.10
Kharagaon 0.00 0.00 0.00 0.00 0.00 -
FSTPS 0.00 0.00 0.00 0.00 0.00 -
KhSTPS I 0.00 0.00 0.00 0.00 0.00 -
RSTPS 0.00 0.00 0.00 0.00 0.00 -
TSTPS 0.00 0.00 0.00 0.00 0.00 -
KHSTPP-II 22.06 1.91 4.85 0.00 6.76 3.07
Subtotal 4,889.52 795.46 1,058.65 0.00 1,854.12 3.79
NSPCL - Bhilai 703.06 121.15 181.93 0.00 303.07 4.31
NSPCL - Rourkela -
-
NPCIL -
KAPS 70.53 0.00 17.19 0.00 17.19 2.44
TAPS 3&4 266.59 0.00 94.91 0.00 94.91 3.56
Subtotal 337.12 0.00 112.10 0.00 112.10 3.33
Others -
RGPPL 0.00 0.00 0.00 0.00 0.00 -
Tata Power - Haldia 0.00 0.00 0.00 0.00 0.00 -
EMCO 0.00 0.00 0.00 0.00 0.00 -
Subtotal 0.00 0.00 0.00 0.00 0.00 -
Total Firm 5,929.69 916.61 1,352.68 0.00 2,269.29 3.83
Power purchase from Other Sources -
Indian E. Exchange/Bilateral 927.00 0.00 315.18 0.00 315.18 3.40
UI 0.00 0.00 0.00 0.00 0.00 -
Solar 6.18 0.00 0.00 0.00 0.00 0.00
Non Solar 175.20 0.00 45.38 0.00 45.38 2.59

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 109
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

All Per
Units Fixed Variable Other
Source Charges Unit
Purchased Charges Charges Charges
Total Cost
Solar REC 0.00 0.00 61.02 0.00 61.02 -
Non Solar REC 0.00 0.00 48.79 0.00 48.79 -
Solar (SECI) 0.00 0.00 0.00 0.00 0.00 -
Wind (SECI) 0.00 0.00 0.00 0.00 0.00 -
Subtotal 1,108.38 0.00 470.36 0.00 470.36 4.24
Misc. Arrears -
Power Purchase Cost 7,038 917 1,823 0 2,740 3.89
External Losses 0.00 -
Availability at ED-DNH Periphery 7038.07 916.61 1823.04 0.00 2739.65 3.89
PGCIL CHARGES 319.58 -
POSOCO 0.58 -
WRPC 0.00 -
Reactive charges 2.55 -
MSTCL 0.00 -
Others 36.00 -
Grand Total of Charges 7,038.07 916.61 1,823.04 0.00 3,098.36 4.40
GMR - Change in Law 0.00 -
Total Power Purchase Cost 3,098.36 -

Commission’s Analysis

The Commission for the purpose of estimating the cost of power purchase for FY 2021-22 has relied on the
station wise actual energy charges for 9 months of FY 2020-21 and cost approved in Tariff Orders for Central
Generating Stations by CERC, which is detailed as follows:

Variable Charges:

• The per unit variable costs for various power stations and Open Market have been computed by
considering the actual per unit variable cost computed for FY 2020-21. 5% escalation has been
considered over the actual per unit variable cost to arrive upon the variable per unit cost for FY 2021-
22.

Fixed Charges:

• The fixed costs have been determined based on the Tariff Orders issued by CERC for respective Central
Generating Stations. The fixed costs approved in FY 2020-21 have been escalated by 2% to arrive at
fixed cost of FY 2021-22.

Other Charges:

The petitioner has not claimed any other charges in relation to the Power Purchase Cost. Since, such claim
has not been made by the petitioner, no other charges have been considered and the same shall be considered
as per actuals during the True-up of FY 2021-22.

Purchase form Power Exchanges:


• For FY 2021-22, the Commission has considered an escalation of 5% on actual average rate of power
purchase from power exchange for first nine months of FY 2020-21.

Purchase form Non-Solar:


• For FY 2021-22, the Commission has considered petitioner estimated variable charges for Non-Solar
power purchase.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 110
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Purchase form Solar (Own Generation):


• The Commission vide Order dated 05.03.2021 determined the Levelized Tariff for Power from Ground
Mounted Solar PV Plants and Roof Top Solar PV Plants for the petitioner.

• In the above said order the Commission further clarified that petitioner has failed to file the petition for
determination of Levelized Tariff of Ground Mounted Solar PV Plants and Roof Top Solar PV Plants in
time. Accordingly, the Commission has allowed the tariff for these plants only prospectively, i.e., from
1st April 2021 onwards. Accordingly, the levelized Tariff for power from ground mounted & rooftop
solar PV plants have been determined by the Commission for FY 2021-22 onwards.

• For FY 2021-22, the Commission has considered a purchase of 6.18 MUs from own solar generation.
Accordingly, in the ARR of FY 2021-22 the Commission has considered the rates approved by the
Commission vide its Order dated 05.03.2021 of solar plants and computed the total power purchase
cost against the approved MUs purchased from solar own generation. Details regarding the same is
provided in table below:

Table 84: Cost of Solar own generation for FY 2021-22 (INR Crore)
DETAILS OF SOLAR OWN GENERATION 2021-22
(I) Ground Mounted Grid Connected Plant

Total Cost
Sr. Plant Installed Total Tariff Rate
Name of Station (INR
No Capacity (kWp) Generation (INR/kWh)
Crore)

1 Velugam Solar Plant 3000 4150900 6.82 2.83


2 Kala Solar Plant 900 1172440 7.12 0.83
Athal Solar Plant - Harsha
3 200 167364 6.82 0.11
Abakus
4 Athal Solar Plant - Goldi Green 200 300651 4.98 0.15
Total-I 4300 5791355 3.93
(II) ROOF TOP PLANTS
Total-II 485 394145 7.12 0.28
Grand Total (I +II) 4785 6185500 4.21

5.7.3. Transmission Charges


Petitioner’s Submission
Transmission charges payable to PGCIL are based on the total capacity allocation in the transmission network.
DNHPDCL has a mix of firm and infirm capacity allocations from various Central Generating Stations which is
revised by the Ministry of Power at regular intervals. Therefore, considering the changing capacity allocation,
DNHPDCL has estimated the transmission charges. For FY 2021-22, the transmission charges payable to ED-
DNH (Transmission Division) have also been considered.

The Petitioner has projected the POC charges for the FY 2021-22 at INR 319.58 Crore, which have been
projected by considering the average monthly bill being received from PGCIL for first 6 months of FY 2020-
21. The transmission charges along with the total power purchase cost for the FY 2021-22 as submitted by
the Petitioner has been given in the following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 111
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 85: Transmission and other Charges submitted by Petitioner for FY 2021-22 (INR Crore)
Particulars Value
Total Power Purchase Cost 2,739.65
PGCIL CHARGES 319.58
POSOCO 0.58
WRPC 0.00
Reactive charges 2.55
MSTCL 0.00
Intra-state transmission charges 36.00
Grand Total of Charges 3,098.36
GMR - Change in Law 0.00
Grand Total of All Charges 3,098.36

Commission’s Analysis

In Technical Validation Session, petitioner informed the Commission that they have claimed lower
Transmission (PGCIL) charges for FY 2021-22 in comparison to actual Transmission (PGCIL) charges for FY
2019-20 & claimed for FY 2020-21 in expectation that the charges will decrease after issuing of new CERC
Sharing of Inter-State Transmission Charges and Losses Regulations 2020. However, the Petitioner further
submitted that the actual impact of New Regulation is very minor than the expected. Petitioner requested the
Commission to reconsider the Transmission Charges and approve the same as claimed for FY 2020-21.

Accordingly, the Commission has considered the same transmission charges payable to PGCIL for FY 2021-22
as approved for FY 2020-21 without any escalation. The transmission charges for FY 2021-22 have been given
in the table below:

Table 86: Transmission charges (INR Crore) approved for FY 2021-22


Particulars Value
Total Power Purchase Cost 2,711.97
PGCIL CHARGES 468.27
POSOCO 0.54
WRPC 0.00
Reactive charges 1.63
MSTCL 0.00
Intra-state transmission charges 51.73
Grand Total of Charges 3234.13
GMR - Change in Law 0.00
Grand Total of All Charges 3234.13

The Intra-state Transmission Charges are considered from the Transmission Order of DNH-T for FY 2021-22
and other charges are kept same as that estimated by Commission for FY 2020-21. Further, the same shall be
trued up as per actuals.

5.7.4. Total power purchase quantum and cost approved by Commission


Accordingly, based on the above, the energy availability and the power purchase cost approved by the
Commission for FY 2021-22 have been shown in the following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 112
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 87: Power Purchase Quantum and Cost approved by the Commission for FY 2021-22
Variable Fixed Total
Units Per Unit
Sl. Charges Charges Charges
Details of The Stations Purchased Cost
No. (INR (INR (INR
(MUs) (INR/kWh)
Crore) Crore) Crore)
A NTPC Stations
1 KSTPP 1&2 358.60 58.05 24.91 82.97 2.31
2 KSTPS 3
159.36 25.92 21.83 47.76 3.00
3 VSTPP-I 292.12 53.36 24.92 78.28 2.68
4 VSTPP-II
220.12 38.28 15.92 54.20 2.46
5 VSTPP- III 248.76 44.14 25.51 69.65 2.80
6 VSTPP- IV 322.02 55.86 50.61 106.47 3.31
7 KAWAS
277.35 55.56 51.35 106.90 3.85
8 JGPP 210.72 46.36 45.98 92.33 4.38
9 Sipat-I 603.87 98.42 81.68 180.10 2.98
10 Sipat-II
222.27 36.82 27.18 64.00 2.88
11 MSTPL 1 191.77 55.70 60.22 115.92 6.04
12 VSTPS-V 179.26 32.40 30.03 62.43 3.48
13 Mauda 2
225.67 68.92 61.63 130.56 5.79
14 Solapur 356.47 108.21 86.37 194.58 5.46
15 LARA 246.81 54.48 62.30 116.78 4.73
16 Gadarwara
283.95 76.77 57.50 134.27 4.73
17 BARH 0.00 0.00 0.00 0.00 0.00
18 Kharagaon 466.04 136.46 85.55 222.01 4.76
19 KHSTPP-II
19.95 4.48 1.75 6.24 3.13
Subtotal NTPC 4,885.13 1,050.19 815.26 1,865.45 3.82

B NSPCL Bhilai 703.06 191.46 118.99 310.46 4.42

C NPCIL

1 KAPS 65.65 15.92 0.00 15.92 2.42


2 TAPS 266.59 94.92 0.00 94.92 3.56
Subtotal NPCIL
332.23 110.84 0.00 110.84 3.34

D Others
EMCO 0.00 0.00 0.00 0.00 0.00
Subtotal 0.00 0.00 0.00 0.00 0.00
Total Firm Sources 5,920.42 1,352.49 934.25 2286.74 3.86

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 113
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Variable Fixed Total


Units Per Unit
Sl. Charges Charges Charges
Details of The Stations Purchased Cost
No. (INR (INR (INR
(MUs) (INR/kWh)
Crore) Crore) Crore)

E Power purchase from Other


Sources

1 Indian E.
Exchange/Bilateral 927.00 279.98 0.00 279.98 3.02

2 UI
0.00 0.00 0.00 0.00 0.00
3 Solar 0.00 0.00 0.00 0.00 0.00
4 Non Solar 175.20 45.38 0.00 45.38 2.59
5 Solar REC
0.00 51.71 0.00 51.71 0.00
6 Non Solar REC 0.00 41.35 0.00 41.35 0.00
7 Solar (SECI) 0.00 0.00 0.00 0.00 0.00
8 Wind (SECI)
0.00 0.00 0.00 0.00 0.00
9 Own Solar 6.18 4.21 0.00 4.21 6.81
10 Open Market
8.61* 2.60 0.00 2.60 3.02
Subtotal 1,116.99 425.22 0.00 425.22 3.81

F Other Charges
1 PGCIL CHARGES 468.27
2 POSOCO 0.54
3 WRPC
0.00
4 Reactive charges 1.63
5 MSTCL 0.00
6 Intra State Transmission
Charges 51.73

Subtotal
522.17
Grand Total of Charges 7,037.41 3,234.13 4.60
* This power is purchase from Open Market to meet the deficit as approved in Table 81 (Energy Balance approved by the Commission).

The Commission approves the quantum of power purchase as 7,037.41 MU at the generator
periphery with a total cost of INR 3,234.13 Crore for FY 2021-22.

The Average Power Purchase Cost (APPC) for FY 2021-22 has been computed at the DNH Periphery excluding
the transmission charges and cost of purchase of renewable energy (including the costs for Renewable energy
certificates). The same shall be used for the purpose of compensation / payment of surplus power at the end of
each settlement period in case of Net-metering consumers by the Petitioner.

The APPC for FY 2021-22 has been determined as provided in the following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 114
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 88: Average Power Purchase Cost (APPC) approved for FY 2021-22
Particulars Value
Total Power Purchase Cost (INR Crore) 3234.13
Less: Transmission charges and Power Purchase cost from renewable energy sources
664.80
(INR Crore)
Net Power Purchase Cost (INR Crore) 2569.33
Total Power Purchase quantum (MU) 7037.41
Less: Quantum from renewable energy sources (MU) 181.38
Quantum of energy at State Periphery excluding quantum from renewable energy
6856.03
sources (MU)
APPC (INR/kWh) 3.75

The Commission approves the Average Power Purchase Cost (APPC) as INR 3.75/kWh for the
FY 2021-22.

Renewable Purchase Obligation (RPO)


Petitioner’s submission

The Petitioner is required to procure power from renewable sources for meeting the RPO. The RPO
requirement for FY 2021-22 as submitted by the Petitioner has been provided in the following table:

Table 89: RPO Plan proposed by the Petitioner for FY 2021-22 (MU)
Particulars Value
Sales within State (MU) 6,540.77
RPO obligation (%) 17.00%
Solar 8.00%
Non-Solar 9.00%
RPO obligation for the year (MU) 1,111.93
Solar 523.26
Non-Solar 588.67
RPO Compliance (Procurement and own generation) 180.38
Solar 6.18
Non-Solar 175.20
RPO Compliance (REC certificate purchase)
930.55
Solar
517.08
Non-Solar
413.47

Commission’s Analysis

As per Clause 1, Sub-clause (1) of the JERC for the State of Goa and UTs (Procurement of Renewable Energy)
Regulations, 2010:

“(1.1) Each distribution licensee shall purchase electricity (in kWh) from renewable energy sources, at a
defined minimum percentage of the total consumption of all the consumers in its area during a year.”

The Commission notified the JERC (Procurement of Renewable Energy), (Third Amendment) Regulations,
2016 on 22nd August 2016 and approved the revised RPO targets, as per which the Petitioner has to purchase

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 115
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

17.00% of its total consumption (including 8.00% from Solar & 9.00% from Non Solar) from renewable sources
for the FY 2021-22.

The total cost towards RPO compliance has been considered in the total power purchase cost approved earlier.

In FY 2021-22, the Petitioner has projected fulfillment of the RPO obligation completely by actual purchase of
renewable power. The Petitioner projected to purchase (& Generate) 523.26 MU of solar power and 588.67 MU
of non-solar power. The Commission acknowledges the effort on the Petitioner part to plan to purchase the
renewable power from actual power plants instead of only relying on RECs and also focusing on fulfilling the
RPO obligation for the year.

In accordance with the JERC for the State of Goa and UTs (Procurement of Renewable Energy) Regulations,
2010 the Commission has determined the following Renewable Purchase Obligation for the Petitioner for the
FY 2021-22:

Table 90: RPO targets and compliance plan approved by the Commission for FY 2021-22 (MU)
Sr. No. Particulars Formulae Value

A Solar Target 8.00%


B Non-Solar Target 9.00%
C Total RPO Target C=A+B 17.00%

D Sales Within UT 6,540.77

E RPO Obligation for the year E=F+G 1111.93


F Solar F=D*A 523.26
G Non-Solar G=D*B 588.67

H Physical RE Purchase H=I+J 181.38


I Solar 6.18
J Non-Solar 175.20

K REC Purchase K=L+M 930.55


L Solar 517.08
M Non-Solar 413.47

N Total RPO Compliance for FY 2021-22 (REC+ Physical RE) N=O+P 1111.93
O Solar O=I+L 523.26
P Non-Solar P=J+M 588.67

Q Standalone shortfall/(surplus) for FY 2021-22 Q=R+S 0.00


R - Solar R=F-O 0.00
S - Non-Solar S=G-P 0.00

T Backlog upto FY 2020-21 T=U+V 1366.05


U - Solar 545.30
V - Non-Solar 820.75

W Total Shortfall/(surplus) in RPO Compliance for FY 2021-22 W=X+Y 1366.05

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 116
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Sr. No. Particulars Formulae Value

X Solar X=R+U 545.30


Y Non-Solar Y=S+V 820.75

Similar to the approach followed in the APR of FY 2020-21, the Commission has considered the gross energy
generated from solar rooftop plants while approving the RPO compliance for the year.

In last Tariff Order for FY 2020-21 dated 18th May 2020, the Commission had approved cost against cumulative
RPO shortfall till FY 2020-21. However, as per the actual data submitted by the petitioner for FY 2020-21 till
Jan’21, the petitioner did not purchase any quantity of Solar & Non-Solar RECs. Secondly for FY 2021-22 in
power purchase cost petitioner claimed purchase of RE certificates for standalone gap only.

The Commission has considered the standalone shortfall for FY 2021-22 to be fulfilled by way of REC purchase
and has assumed the rate of purchase for Non-Solar REC & Solar REC as INR 1.00/kWh (IEX Capping Rate).
Accordingly, the Commission has approved cost for INR 93.06 Crore towards compliance of RPO shortfall. The
cost has already been considered in the total power purchase cost approved by the Commission in the previous
section. The same shall be trued-up on actual basis during the True-up. Further, the Commission directs
the petitioner to fulfill the RPO obligation in future years by either purchasing power from
Renewable energy sources or by purchasing RECs.

Operation & Maintenance Expenses


The Operation & Maintenance Expenses comprise of the Employee Expenses, Administrative and General
Expenses (A&G) and the Repair & Maintenance Expenses (R&M).

Regulation 51 of the MYT Regulation, 2018 states the following:

“51. Operation and Maintenance (O&M) expenses for the Distribution Wires Business
51.1 The Operation and Maintenance expenses for the Distribution Wires Business shall be computed in
accordance with this Regulation.
51.2 Operation and Maintenance (O&M) expenses shall comprise of the following:
a) Employee expenses - salaries, wages, pension contribution and other employee costs;
b) Administrative and General expenses including insurance charges if any; and
c) Repairs and Maintenance expenses.
51.3 The Distribution Licensee shall submit the required O&M expenses for the Control Period as a part of
Multi Year Tariff Petition. O&M expenses for the base Year shall be approved by the Commission taking into
account the latest available audited accounts, business plan filed by the transmission Licensee, estimates of
the actuals for the Base Year, prudence check and any other factors considered appropriate by the
Commission.
51.4 O&M expenses for the nth Year of the Control Period shall be approved based on the formula given
below:
O&Mn = (R&Mn + EMPn + A&Gn) x (1 - Xn) + Terminal Liabilities
Where,
R&Mn = K x GFAn-1 x (WPI inflation)
EMPn = (EMPn-1) x (1+Gn) x (CPI inflation)
A&Gn = (A&Gn-1) x (CPI inflation)

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 117
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

‘K’ is a constant (expressed in %). Value of K for each Year of the Control Period shall be determined by the
Commission in the Multi Year Tariff Order based on Licensee’s filing, benchmarking of repair and
maintenance expenses, approved repair and maintenance expenses vis-à-vis GFA approved by the
Commission in past and any other factor considered appropriate by the Commission;
CPI inflation – is the average increase in Consumer Price Index (CPI) for immediately preceding three (3)
Years before the base Year;
WPI inflation – is the average increase in the Wholesale Price Index (CPI) for immediately preceding three (3)
Years before the base Year;
EMPn – Employee expenses of the Distribution Licensee for the nth Year;
A&Gn – Administrative and General expenses of the Distribution Licensee for the nth Year;
R&Mn – Repair and Maintenance expenses of the Distribution Licensee for the nth Year;
GFAn-1 – Gross Fixed Asset of the transmission Licensee for the n-1th Year;
Xn is an efficiency factor for nth Year. Value of Xn shall be determined by the Commission in the Multi Year
Tariff Order based on Licensee’s filing, benchmarking, approved cost by the Commission in past and any
other factor the Commission feels appropriate;
Gn is a growth factor for the nth Year. Value of Gn shall be determined by the Commission for each Year in
the Multi Year Tariff Order for meeting the additional manpower requirement based on Licensee’s filings,
benchmarking, and approved cost by the Commission in past and any other factor that the Commission feels
appropriate:
Provided that in case the Distribution Licensee has been in operation for less than three (3) Years as on the
date of effectiveness of these Regulations, O&M Expenses shall be determined on case to case basis.
51.5 Terminal liabilities of employees of Licensee including pension expenses etc. shall be approved as per
actuals submitted by the Licensee, subject to prudence check or be established through actuarial studies.
Additionally, any variation due to changes recommended by the pay commission shall be allowed separately
by the Commission, subject to prudence check.
51.6 For the purpose of estimation, the same value of factors – CPI inflation and WPI inflation shall be used
for all Years of the Control Period. However, the Commission shall consider the actual values of the factors –
CPI inflation and WPI inflation during the truing up exercise for the Year for which true up is being carried
out and true up the O&M Expenses for that Year, only to the extent of inflation.

5.9.1. Employee Expenses

Petitioner’s submission

The employee expenses comprise of basic salary, dearness allowances, medical cost, leave travel allowances,
honorarium, etc. No cost related to leave salary contribution and pension of the employee has been projected by
the petitioner and the Commission has been requested to consider the same at the time of True-up on actual
basis.

The table below provides the employee expenses projected for FY 2021-22 by the Petitioner:

Table 91: Employee Expenses submitted by Petitioner for FY 2021-22 (INR Crore)
Approved in ARR Petitioner
Particular
order Submission
Employee Expenses 18.95 14.38

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 118
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

In accordance with the MYT Regulations, 2018, the Commission has determined the Employee expenses for FY
2021-22. The Regulation 6 of the MYT Regulations, 2018 stipulates the following:

“6. Values for Base Year

6.1 The values for the Base Year of the Control Period shall be determined on the basis of the audited accounts
or provisional accounts of last three (3) Years, and other factors considered relevant by the Commission:

Provided that, in absence of availability of audited accounts or provisional accounts of last three (3) Years,
the Commission may benchmark the parameters with other similar utilities to establish the values for Base
Year:

Provided, further that the Commission may change the values for Base Year and consequently the trajectory
of parameters for Control Period, considering the actual figures from audited accounts.”

As above, Regulation 6 provides that the Commission may change the values for Base Year considering the
actual figures from audited accounts. As the Commission in this Order has carried out the truing up for FY
2019-20 based on audited accounts, the Commission has considered the trued-up employee expenses for FY
2019-20 as base expenses and applied the CPI Inflation for approving the revised employee expenses for FY
2020-21 and then for FY 2021-22.

The CPI Inflation has been computed as follows:

Table 92: Computation of CPI Inflation (%)


Increase in CPI Average increase in CPI
FY Average of (Apr-Mar)
Index indices over 3 years
2017-18 284.58 3.14%
2018-19 299.92 5.39%
2019-20 322.50 7.53%
CPI Inflation 5.35%

As per the details submitted by the Petitioner, the estimated growth in number of employees for FY 2021-22 is
0.27%. Hence, the Commission has considered the revised growth in employee expenses for FY 2021-22 while
projecting the employee expenses for FY 2021-22.

Accordingly, the employee expenses approved by the Commission for the FY 2021-22 have been provided in the
following table:

Table 93: Employee Expenses approved by Commission for FY 2021-22 (INR Crore)
S. No Particulars Value
1 Employee Expenses approved for FY 2020-21 (EMPn-1) 13.95
2 Growth in number of employees (Gn) 0.27%
3 CPI Inflation for preceding three years (CPI) 5.35%
Employee Expenses
14.73
(EMPn) = (EMPn-1) x (1+Gn) x (1+CPI inflation)

The Commission approves Employee Expenses of INR 14.73 Crore FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 119
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

5.9.2. Administrative and General (A&G) Expenses

Petitioner’s submission

The Petitioner has submitted that the Administrative and General (A&G) expense comprise of various sub-
heads including the following:
• Telephone, postage & telegrams charges;
• Travel and conveyance expenses;
• Consultancy and regulatory fees; and
• Consumer indexing fee

For projecting the A&G Expenses for FY 2021-22, the petitioner has been used formula as given in MYT
Regulations. The A&G Expenses as submitted by the Petitioner & as approved by the Commission for FY 2021-
22 in its MYT order for FY 2021-22 are given below:

Table 94: A&G Expenses submitted by Petitioner for FY 2021-22 (INR Crore)
Approved in ARR Petitioner
Particular
order Submission
A&G expenses 7.57 8.11

Commission’s Analysis

Similar to the methodology followed while estimating the employee expenses, the Commission has considered
the trued-up A&G expenses for FY 2019-20 as Base Year expenses and escalated the same with CPI Inflation for
approving the revised trajectory of A&G expenses for FY 2020-21 and then for FY 2021-22.

The A&G expenses approved by the Commission for FY 2021-22 have been provided in the following table:

Table 95: A&G Expenses approved by Commission for FY 2021-22 (INR Crore)
S. No Particulars Value
1 A&G Expenses approved for FY 2020-21 (A&Gn-1) 6.62
2 CPI Inflation 5.35%
A&G Expenses
3 6.97
A&Gn = (A&Gn-1) x (1+CPI inflation)

The Commission approves the Administrative & General (A&G) expenses of INR 6.97 Crore for
FY 2021-22.

5.9.3. Repair & Maintenance Expenses (R&M)

Petitioner’s submission

The Petitioner submitted that Repairs and Maintenance expense comprise of expenses incurred by them with
regard to maintenance and upkeep of the transmission and distribution system. Adequate R&M activities help
in reduction of transmission and distribution losses and breakdowns in the system.

The Petitioner has determined the R&M expenses based on the norms specified in the MYT Regulations, 2018.
The average increase in Wholesale Price Index (WPI) has been calculated based on the increase in the
Wholesale Price Index (WPI) for FY 2017-18, FY 2018-19 & FY 2019-20 as 2.96%.

Table 96: R&M expenses submitted by Petitioner for FY 2021-22 (INR Crore)
Approved in ARR
Particular Petitioner Submission
order
R&M Expenses 12.64 25.61

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 120
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

Regulation 51.4 of the JERC MYT Regulation, 2018 states as shown below:

“……..
‘K’ is a constant (expressed in %). Value of K for each Year of the Control Period shall be determined by the
Commission in the Multi Year Tariff Order based on Licensee’s filing, benchmarking of repair and
maintenance expenses, approved repair and maintenance expenses vis-à-vis GFA approved by the
Commission in past and any other factor considered appropriate by the Commission;
……”
As provided in clause 51.4 of the JERC MYT Regulations, 2018 the Commissions has considered the value of ‘K’
factor as 2.03% which was approved by the Commission in MYT order dated 20 th May 2019 for FY 2021-22.

Further as per the provisions of the JERC MYT Regulations, 2018, the WPI Inflation has been computed as
follows:

Table 97: Computation of WPI Inflation (%)


Increase in WPI Average increase in WPI
FY Average of (Apr-Mar)
Index indices over 3 years
2017-18 114.88 2.92%
2018-19 119.79 4.28%
2019-20 121.80 1.68%
WPI Inflation 2.96%

The R&M expenses approved by the Commission for FY 2021-22 have been provided in the following table:

Table 98: R&M Expenses approved by Commission for FY 2021-22 (INR Crore)
S. No Particulars Value
1 GFA of previous year, i.e., FY 2020-21 (GFAn-1) 625.53
2 K factor approved (K) 2.03%
3 WPI Inflation 2.96%
R&M Expenses = (K x (GFA n-1) x (1+WPIinflation) 13.07

The Commission approves the Repair & Maintenance (R&M) expenses of INR 13.07 Crore for FY
2021-22.

5.9.4. Total Operation and Maintenance Expenses (O&M)


The following table provides the total O&M expenses approved by the Commission for FY 2021-22:

Table 99: O&M Expenses approved by Commission for FY 2021-22 (INR Crore)
Approved in Petitioner’s Now Approved
S. No Particulars
MYT Order Submission by Commission
1 Employee Expenses 18.95 14.38 14.73
2 A&G Expenses 7.57 8.11 6.96
3 R&M Expenses 12.64 25.61 13.07
4 Total O&M Expenses 39.16 48.10 34.78

The Commission approves the Operation & Maintenance (O&M) expenses of INR 34.78 Crore
for FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 121
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Gross Fixed Assets (GFA) and Capitalization


Petitioner’s submission

The Petitioner has requested the Commission to approve the capital expenditure and capitalization as given in
table as follows:

Table 100: Capital Expenditure and Capitalization proposed by the Petitioner for FY 2021-22 (INR Crore)
S. No. Particulars Total Scheme Amount
1 Capital Expenditure 18.00
2 Capitalization 48.00

Commission’s Analysis

The Commission with regard to the capital expenditure and capitalization proposed to be undertaken during
the year, directed the Petitioner to submit the scheme wise Detailed Project Reports (DPR) and the copy of the
Technical Sanctions accorded to each scheme. The Petitioner in response submitted the supporting documents
w.r.t. the scheme wise capital expenditure and capitalization along with the copy of the technical sanctions. The
Petitioner has considered the approved capex and capitalization of INR 18.00 Crore and INR 48.00 Crore
respectively as approved in the Business Plan Order dated November 5, 2018. Based on the details submitted by
the Petitioner, the Commission at this stage approves the Capital Expenditure and Capitalization as proposed
by the Petitioner, which shall be subject to truing up based on actuals.

The Capitalization and Capital Expenditure approved by The Commission is given below:

Table 101: Capital Expenditure and Capitalization approved by the Commission for FY 2021-22 (INR Crore)
Approved in MYT Petitioner's Now Approved by
S. No Particulars
Order Submission Commission
1 Capital Expenditure 18.00 18.00 18.00
2 Capitalization 48.00 48.00 48.00

The Commission approves capital expenditure of INR 18.00 Crore and capitalization of INR
48.00 Crore in the ARR of the FY 2021-22.

5.10.1. Analysis of GFA and capitalization for the control period (FY
2019-20 to FY 2021-22)
As per MYT order dated 20th May 2019, the Commission approved total Capital Expenditure of INR 176.39
Crore and Capitalization of INR 236.39 Crore for the control period from FY 2019-20 to FY 2021-22. In this
tariff order the Commission has approved total Capital Expenditure of INR 91.08 Crore and total Capitalization
of INR 221.17 Crore only. Hence the Capital Expenditure & Capitalization approved till now is within limit of
the capitalization approved in Business plan order/MYT order.

The year wise details of Capital Expenditure & Capitalization are provided below:

Table 102: Analysis of GFA and capitalization for the control period (FY 2019-20 to FY 2021-22)
Approved in MYT Order Now Approved by Commission
S.
Particulars FY FY FY FY 2019- FY FY
No Total Total
2019-20 2020-21 2021-22 20 2020-21 2021-22

Capital
1 128.20 30.19 18.00 176.39 42.89 30.19 18.00 91.08
Expenditure
2 Capitalization 5.70 182.69 48.00 236.39 14.48 158.69 48.00 221.17

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 122
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Capital Structure
Petitioner’s Submission

The Petitioner submitted that capitalization of INR 48.00 Crore shall be undertaken in FY 2021-22. Further,
the entire capital deployment by Petitioner shall be through equity.

Commission’s Analysis

The Regulation 26 of the MYT Regulations, 2018 stipulates the following:

26. Debt to Equity Ratio

26.1 In case of Existing Projects, debt to equity ratio allowed by the Commission for determination of tariff for
the period ending March 31, 2018 shall be considered:

Provided that in case of retirement or replacement or De-capitalization of the assets, the equity capital
approved as mentioned above, shall be reduced to the extent of 30% (or actual equity component based on
documentary evidence, if it is lower than 30%) of the original cost of such assets:

Provided, further that in case of retirement or replacement or De-capitalization of the assets, the debt capital
approved as mentioned above, shall be reduced to the extent of outstanding debt component based on
documentary evidence, or the normative loan component, as the case may be, of the original cost of such
assets.

26.2 For New Projects, the debt-equity ratio as on the Date of Commercial Operation shall be 70:30 of the
amount of capital cost approved by the Commission under Regulation 23, after prudence check for
determination of tariff:

Provided that where equity actually deployed is less than 30% of the capital cost of the capitalized asset, the
actual equity shall be considered for determination of tariff:

Provided also that if the equity actually deployed is more than 30% of the capital cost, equity in excess of 30%
shall be treated as a normative loan for the Licensee for determination of tariff:

Provided also that the Licensee shall submit documentary evidence for the actual deployment of equity and
explain the source of funds for the equity:

Provided also that the equity invested in foreign currency shall be designated in Indian rupees on the date of
each investment:

Provided further that the premium, if any, raised by the Licensee while issuing share capital and investment
of internal resources created out of its free reserves, for the funding of the scheme, shall be reckoned as paid
up capital for the purpose of computing return on equity, provided such premium amount and internal
resources are actually utilized for meeting the capital expenditure of the transmission system or the
distribution system, and are within the ceiling of 30% of capital cost approved by the Commission.

26.3 Any expenditure incurred or projected to be incurred on or after April 1, 2019, as may be admitted by the
Commission, as additional capital expenditure for determination of tariff, and renovation and modernization
expenditure for life extension shall be serviced in the manner specified in this Regulation.”

In accordance with above, since the Petitioner has submitted that the entire capitalization is funded through
equity, thus equity higher than 30% of capitalization has been considered as normative loan. The opening Gross
Fixed Assets for FY 2021-22 has been considered as closing Gross Fixed Assets approved in the APR of FY

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 123
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

2020-21. Further, the values of opening loan and equity has been considered as closing loan and equity
approved in APR of FY 2020-21. The loan and equity addition have been considered on normative basis as 70%
and 30% respectively of the approved capitalization for the year.

In accordance with the MYT Regulations, 2018, the Commission has determined the Capital Structure for the
FY 2021-22 as detailed below:

Table 103: GFA addition approved by the Commission (INR Crore) for FY 2021-22
Approved in Petitioner's Now Approved by
S. No Particulars
MYT Order Submission Commission
1 Opening Gross Fixed Assets 621.34 649.53 625.53
2 Addition During FY 48.00 48.00 48.00
3 Adjustment/Retirement During FY 0.00 0.00 0.00
4 Closing Gross Fixed Assets 669.34 649.53 673.53

Table 104: Normative Loan addition approved by the Commission for FY 2021-22 (INR Crore)
Approved in Petitioner's Now Approved by
S. No Particulars
MYT Order Submission Commission
1 Opening Normative Loan 107.37 133.38 112.75
2 Add: Normative Loan During the year 33.6 33.6 33.60
Less: Normative Repayment
3 24.98 24.27 21.34
equivalent to Depreciation
4 Closing Normative Loan 115.99 142.71 125.01

Table 105: Normative Equity addition approved by the Commission for FY 2021-22 (INR Crore)
Approved in Petitioner's Now Approved by
S. No Particulars
MYT Order Submission Commission
1 Opening Equity 150.78 194.86 152.03
Additions on account of new
2 14.40 14.40
capitalization 14.40
3 Closing Equity 165.18 209.26 166.43

Depreciation
Petitioner’s submission

The Petitioner has submitted the depreciation considering the depreciation rate as per MYT Regulations, 2018.

The following table provides the depreciation for FY 2021-22:

Table 106: Depreciation as submitted by the Petitioner for FY 2021-22 (INR Crore)
S. No. Particulars Value
1 Opening GFA 649.53
2 Additions 48.00
3 Closing GFA 649.53
4 Average GFA 649.53
5 Depreciation Amount 24.27

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 124
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

Regulation 30 of the MYT Regulations, 2018 stipulates the following:

“30. Depreciation

30.1 The value base for the purpose of depreciation shall be the capital cost of the asset admitted by the
Commission:

Provided that the depreciation shall be allowed after reducing the approved original cost of the retired or
replaced or decapitalized assets:

Provided, also that the no depreciation shall be allowed on the assets financed through consumer
contribution, deposit work, capital subsidy or grant.

30.2 The salvage value of the asset shall be considered as 10% and depreciation shall be allowed up to a
maximum of 90% of the capital cost of the asset.

30.3 Land other than the land held under lease shall not be a depreciable asset and its cost shall be excluded
from the capital cost while computing depreciable value of the assets.

30.4 In case of existing assets, the balance depreciable value as on April 1, 2019, shall be worked out by
deducting the cumulative depreciation as admitted by the Commission up to March 31, 2018, from the gross
depreciable value of the assets.

30.5 The depreciation shall be chargeable from the first Year of commercial operations. In case of projected
commercial operation of the assets during the Year, depreciation shall be computed based on the average of
opening and closing value of assets:

Provided that depreciation shall be re-calculated during truing-up for assets capitalized at the time of truing
up of each Year of the Control Period, based on documentary evidence of asset capitalized by the Applicant,
subject to the prudence check of the Commission.

30.6 For Transmission Licensee, the depreciation shall be calculated at rates and norms specified in the
prevalent CERC Tariff Regulations for transmission system.

30.7 The depreciation for a Distribution Licensee shall be calculated annually, based on the Straight Line
Method, over the Useful Life of the asset at rates specified in Appendix I of the Regulations.

30.8 In addition to allowable depreciation, the Distribution Licensee shall be entitled to advance against
depreciation (AAD), computed in the manner given hereunder:

AAD = Loan (raised for capital expenditure) repayment amount based on loan repayment tenure, subject to a
ceiling of 1/10th of loan amount minus depreciation as calculated on the basis of these Regulations:

Provided that advance against depreciation shall be permitted only if the cumulative repayment upto a
particular Year exceeds the cumulative depreciation upto that Year:

Provided, further that advance against depreciation in a Year shall be restricted to the extent of difference
between cumulative repayment and cumulative depreciation upto that Year.

30.9 The Distribution Licensee shall provide the list of assets added during each Year of Control Period and
list of assets completing 90% of depreciation in the Year along with Petition for annual performance review,
true-up and tariff determination for ensuing Year.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 125
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

30.10 The remaining depreciable value for a Distribution Licensee shall be spread over the balance useful life
of the asset, on repayment of the entire loan.”

The Commission has derived the weighted average rate of depreciation based on the asset wise depreciation
rate specified in MYT Regulations, 2018, provided in the following table:

Table 107: Depreciation Rate (%)


Description Rate
Plant & Machinery 3.60%
Underground cables 2.57%
Buildings 1.80%
Vehicles 18.00%
Furniture & Fixtures 6.00%
Computers & Others 6.00%
Land 0.00%
Software-Intangible assets 15.00%

The opening and closing GFA has been considered as approved in Section 5.11: Capital Structure of this Order,
adjusted by value of assets that have achieved 90% depreciation. Further, deprecation for FY 2021-22 has been
computed on average Gross Fixed Assets (GFA) after considering the net addition proposed during the year.
The overall depreciation rate is considered as the weighted average depreciation rate calculated based on the
computed asset wise depreciation and average GFA.

The following table provides the calculation of deprecation approved for FY 2021-22:

Table 108: Depreciation approved by Commission for FY 2021-22 (INR Crore)


Approved in MYT Petitioner's Now Approved by
S. No Particulars
Order Submission Commission
1 Opening GFA for FY 2021-22 621.34 649.53 625.53
2 Addition During FY 48.00 48.00 48.00
3 Adjustment/Retirement During FY 0.00 0.00 0.00
4 Closing Gross Fixed Assets 669.34 649.53 673.53
5 Average Gross Fixed Assets 645.34 649.53 649.53
6 Effective Rate of Depreciation (%) 3.87% 3.74% 3.29%
7 Depreciation 24.98 24.27 21.34

The Depreciation approved by the Commission is lower as compared to the Petitioner’s claim due to difference
in opening GFA as considered by the Commission and as taken by the Petitioner. The Commission has
considered the opening GFA for FY 2021-22 same as the closing GFA of previous year, i.e., FY 2020-21, as per
MYT Regulations, 2018.

Accordingly, the Commission approves depreciation of INR 21.34 Crore in the ARR of the FY
2021-22.

Interest on Loan
Petitioner’s submission

The Interest on Loan has been computed on normative basis according to the MYT Regulations, 2018. The
normative loan addition in the FY 2021-22 has been computed as 70% of the capitalization proposed during the
FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 126
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

The repayment of loans has been considered equal to the depreciation during the FY 2021-22. Further the rate
of interest has been considered as SBI MCLR @ 8.75%.

Commission’s Analysis

The Regulation 28 of the MYT Regulations, 2018 specifies the following:

“28. Interest on Loan

28.1 The loans arrived at in the manner indicated in Regulation 26 on the assets put to use, shall be
considered as gross normative loan for calculation of interest on the loan:

Provided that interest and finance charges on capital works in progress shall be excluded:

Provided, further that in case of De-capitalization or retirement or replacement of assets, the loan capital
shall be reduced to the extent of outstanding loan component of the original cost of the de-capitalized or
retired or replaced assets, based on documentary evidence.

28.2 The normative loan outstanding as on April 1, 2019, shall be worked out by deducting the cumulative
repayment as admitted by the Commission up to March 31, 2018, from the gross normative loan.

28.3 Notwithstanding any moratorium period availed by the Transmission Licensee or the Distribution
Licensee, as the case may be, the repayment of loan shall be considered from the first Year of commercial
operation of the project and shall be equal to the annual depreciation allowed in accordance with Regulation
30.

28.4 The rate of interest shall be the weighted average rate of interest calculated on the basis of the actual
loan portfolio at the beginning of each Year applicable to the Transmission Licensee or the Distribution
Licensee:

Provided that at the time of truing up, the weighted average rate of interest calculated on the basis of the
actual loan portfolio during the Year applicable to the Transmission Licensee or the Distribution Licensee
shall be considered as the rate of interest:

Provided also that if there is no actual loan for a particular Year but normative loan is still outstanding, the
last available weighted average rate of interest for the actual loan shall be considered:

Provided further that if the Transmission Licensee or the Distribution Licensee does not have actual loan, then
one (1) Year State Bank of India (SBI) MCLR / any replacement thereof as notified by RBI for the time being
in effect applicable for one (1) Year period, as may be applicable as on 1st April of the relevant Year plus 100
basis points shall be considered as the rate of interest for the purpose of allowing the interest on the
normative loan.

28.5 The interest on loan shall be calculated on the normative average loan of the Year by applying the
weighted average rate of interest:

Provided that at the time of truing up, the normative average loan of the Year shall be considered on the basis
of the actual asset capitalization approved by the Commission for the Year.

28.6 For new loans proposed for each Financial Year of the Control Period, interest rate shall be considered
as lower of (i) one (1) Year State Bank of India (SBI) MCLR / any replacement thereof as notified by RBI for
the time being in effect applicable for one (1) Year period, as may be applicable as on 1st April of the relevant
Year plus 100 basis points, and (ii) weighted average rate of interest proposed by the Distribution Licensee.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 127
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

28.7 The above interest computation shall exclude the interest on loan amount, normative or otherwise, to the
extent of capital cost funded by consumer contribution, deposit work, capital subsidy or grant, carried out by
Transmission Licensee or Distribution Licensee.

28.8 The finance charges incurred for obtaining loans from financial institutions for any Year shall be
allowed by the Commission at the time of Truing-up, subject to prudence check.

28.9 The excess interest during construction on account of time and/or cost overrun as compared to the
approved completion schedule and capital cost or on account of excess drawal of the debt funds
disproportionate to the actual requirement based on Scheme completion status, shall be allowed or disallowed
partly or fully on a case to case basis, after prudence check by the Commission:

Provided that where the excess interest during construction is on account of delay attributable to an agency
or contractor or supplier engaged by the Transmission Licensee, any liquidated damages recovered from
such agency or contractor or supplier shall be taken into account for computation of capital cost:

Provided further that the extent of liquidated damages to be considered shall depend on the amount of excess
interest during construction that has been allowed by the Commission.

28.10 The Transmission Licensee or the Distribution Licensee, as the case may be, shall make every effort to
re-finance the loan as long as it results in net savings on interest and in that event the costs associated with
such re-financing shall be borne by the beneficiaries and the net savings shall be shared between the equally
between the beneficiaries and the Transmission Licensee or the Distribution Licensee and the Consumers of
Distribution Licensee.

28.11 Interest shall be allowed on the amount held as security deposit held in cash from Retail Consumers at
the Bank Rate as on 1st April of the Financial Year in which the Petition is filed:

Provided, that at the time of truing-up, the interest on the amount of security deposit for the Year shall be
considered on the basis of the actual interest paid by the Licensee during the Year, subject to prudence check
by the Commission.”

The Commission has considered the values for opening loan and loan addition as approved in the Section 5.11:
Capital Structure of this Order. Further, the repayment is considered same as depreciation approved for FY
2021-22. In absence of any actual loans, the Commission has considered the 1-year SBI MCLR as on March 10,
2021 (7.00%) plus 100 basis points as rate of interest, in accordance with the JERC MYT Regulations, 2018.

The following table provides the Interest on Loan approved by the Commission for FY 2021-22:

Table 109: Interest on loan approved by Commission for FY 2021-22 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
MYT Order Submission by Commission
1 Opening Normative Loan 107.37 133.38 112.75
2 Add: Normative Loan During the year 33.60 33.60 33.60
Less: Normative Repayment equal to
3 24.98 24.27 21.34
Depreciation
4 Closing Normative Loan 115.99 142.71 125.01
5 Average Normative Loan 111.68 138.05 118.88
6 Rate of Interest (%) 9.55% 9.75% 8.00%
Interest on Loan 10.67 12.08 9.51

The Interest on Loan approved by the Commission is lower than the Petitioner’s claim due to difference in
opening normative loan as considered by the Commission and as taken by the Petitioner. The Commission has
considered the opening normative loan for FY 2021-22 same as closing normative loan of previous year, i.e., FY
2020-21, as per MYT Regulations, 2018.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 128
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Accordingly, the Commission approves Interest on Loan as INR 9.51 Crore in the ARR of the FY
2021-22.

Return on Equity (RoE)


Petitioner’s submission

As per the JERC (Multi Year Tariff) Regulations, 2018, Petitioner is entitled for a Return on Equity (RoE). The
Regulation 27.2 and 27.3 of the MYT Regulations, 2018 stipulate the following:

“27.2 The return on equity for the Distribution Wires Business shall be allowed on the equity capital
determined in accordance with Regulation 26 for the assets put to use at post-tax rate of return on equity
specified in the prevalent CERC Tariff Regulations for transmission system.

27.3 The return on equity for the Retail Supply Business shall be allowed on the equity capital determined in
accordance with Regulation 26 for the assets put to use, at the rate of sixteen (16) per cent per annum.”

The Petitioner has segregated the approved average equity (average of opening and closing equity) into average
equity for Distribution Wires Business and Retail Supply Business based on the Allocation Statement provided
in the MYT Regulations, 2018 i.e. 90% allocation for the Distribution Wires Business and 10% allocation for the
Retail Supply Business. The Petitioner has considered a rate of 15.50% for the Distribution Wires Business (as
per the prevalent CERC Regulations) and a rate of 16% for the Retail Supply Business.

The equity component has been determined in accordance with Regulation 26 of the MYT Regulations, 2018.
The following table provides the ROE for the FY 2021-22, as submitted by the Petitioner:

Table 110: Return on Equity as submitted by the Petitioner for FY 2021-22 (INR Crore)
S. No. Particulars Value
1 Opening Equity 194.86
2 Addition in equity on account of new capitalization 14.40
3 Closing Equity 209.26
4 Average Equity 202.06
5 Average Equity for wire business (90%) 181.85
6 Average Equity for Retail Supply Business (10%) 20.21
7 Return on Equity for Wires Business (%) 15.50%
8 Return on Equity for Retail Supply Business (%) 16.00%
9 Return on Equity for Wires Business 28.19
10 Return on Equity for Retail Supply Business 3.23
11 Return on Equity 31.42

Commission’s Analysis

The Regulation 27.2 and 27.3 of the MYT Regulations, 2018 stipulate the following:

“27.2 The return on equity for the Distribution Wires Business shall be allowed on the equity capital
determined in accordance with Regulation 26 for the assets put to use at post-tax rate of return on equity
specified in the prevalent CERC Tariff Regulations for transmission system.

27.3 The return on equity for the Retail Supply Business shall be allowed on the equity capital determined in
accordance with Regulation 26 for the assets put to use, at the rate of sixteen (16) per cent per annum.”
(Emphasis supplied)

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 129
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Further, in this regard, the Regulation 30(2) of the CERC (Terms and Conditions of Tariff) Regulations, 2019
stipulates the following:

“30. Return on Equity:

………

30.2 Return on equity shall be computed at the base rate of 15.50% for thermal generating station,
transmission system including communication system and run-of river hydro generating station, and at
the base rate of 16.50% for the storage type hydro generating stations including pumped storage hydro
generating stations and run-of river generating station with pondage:
……..” (Emphasis supplied)

The Commission has segregated the approved average equity (average of opening and closing equity) into
average equity for Distribution Wires Business and Retail Supply Business based on the Allocation Statement
provided in the MYT Regulations, 2018, i.e., 90% allocation for the Distribution Wires Business and 10%
allocation for the Retail Supply Business. The Commission has considered a rate of 15.50% for the Distribution
Wires Business (as per the prevalent pre-tax rate of return on transmission system in CERC Regulations) and a
rate of 16% for the Retail Supply Business. The equity component has been determined in accordance with
capital structure as discussed above in Section 5.11: Capital Structure of this Order. The following table
provides the Return on Equity approved for the Control Period:

Table 111: RoE approved by Commission for FY 2021-22 (INR Crore)


Now
Approved in Petitioner's
S. No Particulars Approved by
MYT Order Submission
Commission
1 Opening Equity 150.78 194.86 152.03
2 Additions on account of new capitalization 14.40 14.40 14.40
3 Closing Equity 165.18 209.26 166.43
4 Average Equity 157.98 202.06 159.23
5 Average Equity (Wires Business) 142.18 181.85 143.31
Average Equity (Retail Supply Business)
6 15.80 20.21 15.92
Business)
7 Return on Equity for Wires Business (%) 15.50% 15.50% 15.50%
8 Return on Equity for Retail Supply Business (%) 16.00% 16.00% 16.00%
9 Return on Equity for Wires Business 22.04 28.19 22.21
Return on Equity for Retail Supply
10 2.53 3.23 2.55
Business
11 Total Return on Equity 24.57 31.42 24.76

The Return on Equity approved by the Commission is lower than the petitioner’s claim due to difference in
opening equity as considered by the Commission and as taken by the Petitioner. The Commission has
considered the opening equity for FY 2021-22 same as closing equity of previous year, i.e., FY 2020-21, as per
MYT Regulations, 2018. In FY 2019-20, the petitioner has claimed wrong opening equity (i.e. average of closing
equity of FY 2018-19 instead of closing equity of FY 2018-19).

Accordingly, the Commission approves Return on Equity of INR 24.76 Crore in the ARR of the
FY 2021-22.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 130
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Interest on Security Deposits


Petitioner’s submission

Interest on security deposit of INR 4.20 Crore has been claimed towards payment of interest on consumer
security deposits.

Commission’s Analysis

Regulation 28.11 of the MYT Regulations, 2018 stipulates the following:

“28.11 Interest shall be allowed on the amount held as security deposit held in cash from Retail Consumers at
the Bank Rate as on 1st April of the Financial Year in which the Petition is filed:

Provided, that at the time of truing-up, the interest on the amount of security deposit for the Year shall be
considered on the basis of the actual interest paid by the Licensee during the Year, subject to prudence check
by the Commission.”

The Interest on security deposits as claimed by the petitioner has been approved by the Commission and the
same shall be trued-up on the actual basis. The following table provides the interest on security deposits:

Table 112: Interest on Security Deposits approved by Commission for FY 2021-22 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
MYT Order Submission by Commission
1 Interest on Security Deposit 2.45 4.20 4.20

The Commission approves Interest on Security Deposit as INR 4.20 Crore in the ARR for the FY
2021-22.

Interest on Working Capital


Petitioner’s submission

The interest on working capital has been calculated based on the normative principles outlined in the MYT
Regulations, 2018.

The working capital requirement for the Control Period has been computed considering the following:

• Receivable equivalent to two (2) months of the expected revenue from charges for use of distribution
wires at the prevailing tariff;

• O&M Expenses of one month


• Maintenance Spares at 40% of repair and maintenance expenses for one month

• Less consumer security deposit but excluding Bank Guarantee/Fixed Deposit Receipt
A rate of interest of 9.75% has been considered on the working capital requirement, being the 1 year SBI MCLR
plus 200 basis points. This is in line with the MYT Regulations, 2018 which states as follows:

“The rate of interest on working capital shall be equal one (1) Year State Bank of India (SBI) MCLR / any
replacement thereof as notified by RBI for the time being in effect applicable for one (1) Year period, as may
be applicable as on 1st April of the Financial Year in which the Petition is filed plus 200 basis points.”

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 131
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 113: Interest on Working Capital submitted by the Petitioner for FY 2021-22 (INR Crore)
Particular Value
O&M expense for one month 4.01
Maintenance spares at 40% of R&M for one month 0.85
Receivables for 2 months 595.15
Total 600.01
Less consumer security deposit but excluding Bank Guarantee/Fixed Deposit Receipt 60.63
Net Working Capital required after deduction of Security Deposit 539.28
Interest on Working Capital 52.59

Commission’s Analysis

The Regulation 52 of the MYT Regulations, 2018 stipulates the following:

52. Norms of Working Capital for Distribution Wires Business

52.1 The Distribution Licensee shall be allowed interest on the estimated level of working capital for the
Distribution Wires Business for the Financial Year, computed as follows:

(a) O&M Expenses for one (1) month; plus

(b) Maintenance spares at 40% of repair and maintenance expenses for one (1) month; plus

(c) Receivables equivalent to two (2) months of the expected revenue from charges for use of distribution

wires at the prevailing tariff;

Less:

(d) Amount, if any, held as security deposits under clause (b) of sub-section (1) of Section 47 of the Act from
distribution system users except the security deposits held in the form of Bank Guarantees:

Provided that at the time of truing up for any Year, the working capital requirement shall be re-calculated on
the basis of the values of components of working capital approved by the Commission in the truing up.”

Further, Regulation 31 of the MYT Regulation, 2018 stipulates the following:

“31. Interest on Working Capital

.......

31.3 The interest on working capital shall be a payable on normative basis notwithstanding that the Licensee
has not taken working capital loan from any outside agency or has exceeded the working capital loan based
on the normative figures.

31.4 The rate of interest on working capital shall be equal one (1) Year State Bank of India (SBI) MCLR / any
replacement thereof as notified by RBI for the time being in effect applicable for one (1) Year period, as may
be applicable as on 1st April of the Financial Year in which the Petition is filed plus 200 basis points.”

In accordance with the MYT Regulation, 2018, the Commission has computed the Interest on Working Capital
for FY 2021-22. The rate of interest on working capital is considered as 1-yr SBI MCLR rate as on April 1, 2020
plus 200 basis points (7.75%+2.00% = 9.75%). Accordingly, the interest on working capital has been calculated,
as shown in the following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 132
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 114: Interest on Working Capital approved by Commission for FY 2021-22 (INR Crore)
Approved in Petitioner's Now Approved
S. No Particulars
MYT Order Submission by Commission
1 O&M Expenses for One Month 3.26 4.01 2.90
Maintenance spares at 40% of
2 R&M expenses for one (1) month 0.42 0.85 0.44
Receivables equivalent to two (2)
3 months of the expected revenue 566.67 595.15 556.68
Requirement
Less: Amount, held as security
4 39.19 60.63 60.63
deposits
5 Net Working Capital 531.17 539.38 499.38
6 Rate of Interest (%) 10.15% 9.75% 9.75%
7 Interest on Working Capital 53.91 52.59 48.69

The reason of lesser interest on Working Capital approved by the Commission is due to difference in
‘Receivables equivalent to two (2) months of the expected revenue requirement’, which is calculated on the
estimated revenue at revised tariff whereas the petitioner has considered the same on existing tariff.

Accordingly, the Commission approves the Interest on Working Capital of INR 48.69 Crore in
the ARR of the FY 2021-22.

Income Tax
Petitioner’s submission

The Petitioner has made provision towards Income Tax amounting to INR 26.21 Cr for FY 2021-22.

Commission’s Analysis

Regulation 32 of MYT Regulations, 2018 stipulates the following:

“32. Tax on Income

32.1 The treatment of tax on income for a Transmission Licensee shall be in accordance with the prevalent
CERC Tariff Regulations.

32.2 The Commission in its MYT Order shall provisionally approve Income Tax payable for each Year of the
Control Period, if any, based on the actual income tax paid, including cess and surcharge on the same, if any,
as per latest audited accounts available for the Distribution Licensee, subject to prudence check.

32.3 Variation between Income Tax actually paid, including cess and surcharge on the same, if any, and
approved, if any, on the income stream of the Licensed business of the Distribution Licensees shall be
reimbursed to/recovered from the Distribution Licensees, based on the documentary evidence submitted at
the time of truing up of each Year of the Control Period, subject to prudence check.

32.4 Under-recovery or over-recovery of any amount from the Consumers on account of such tax having been
passed on to them shall be adjusted every Year on the basis of income-tax assessment under the Income-Tax
Act, 1961, as certified by the statutory auditors. The Distribution Licensee may include this variation in its
truing up Petition:

Provided that tax on any income stream other than the core business shall not be a pass-through component
in tariff and tax on such other income shall be borne by the Distribution Licensee.”

For FY 2021-22 the Commission has considered INR 15 Crore towards Income Tax same as approved for FY
2020-21 and the same shall be Trued-up based on the actual income tax paid by the Petitioner.
Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 133
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 115: Income Tax approved by Commission for FY 2021-22 (INR Crore)
Approved in MYT Petitioner's Now Approved
S. No Particulars
Order Submission by Commission
1 Income Tax 0 26.21 15.00

The Commission approves the Income Tax of INR 15 Crore in the ARR of the FY 2021-22.

Provision for Bad & Doubtful Debts


Petitioner’s submission

The Petitioner has not earmarked any provision for bad and doubtful debts for the FY 2021-22.

Commission’s Analysis

The Regulation 62 of the MYT Regulations, 2018 stipulates the following:

“62. Provision for bad and doubtful debts

62.1 The Commission may allow bad debts written off as a pass through in the Aggregate Revenue
Requirement, based on the trend of write off of bad debts in the previous years, subject to prudence check:

Provided that the Commission shall true up the bad debts written off in the Aggregate Revenue Requirement,
based on the actual write off of bad debts excluding delayed payment charges waived off, if any, during the
year, subject to prudence check:

Provided also that the provision for bad and doubtful debts shall be limited to 1% of the annual Revenue
Requirement of the Distribution Licensee:

Provided further that if subsequent to the write off of a particular bad debt, revenue is realized from such bad
debt, the same shall be included as an uncontrollable item under the Non-Tariff Income of the year in which
such revenue is realized.”

As above, the Commission has not considered any Provision for Bad & Doubtful Debts. The same shall be
accounted for as per actuals in the True-up of the FY 2021-22.

Non-Tariff Income
Petitioner’s submission

For projecting the non-tariff income for the FY 2021-22, INR 8.22 Crore has been considered by the petitioner.

Commission’s Analysis:

The Regulation 64 of the MYT Regulations, 2018 stipulates the following:


“64. Non-Tariff Income

64.1 The amount of Non-Tariff Income relating to the retail supply of electricity as approved by the
Commission shall be deducted from the Aggregate Revenue Requirement in calculating the tariff for retail
supply of electricity by the Distribution Licensee:

Provided that the Distribution Licensee shall submit full details of its forecast of Non-Tariff Income to the
Commission along with its application for determination of tariff.

64.2 The Non-Tariff Income shall inter-alia include:


Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 134
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

(a) Income from rent of land or buildings;

(b) Income from sale of scrap;

(c) Income from statutory investments;

(d) Interest on advances to suppliers/contractors;

(e) Rental from staff quarters;

(f) Rental from contractors;

(g) Income from hire charges from contactors and others;

(h) Income from advertisements, etc.;

(i) Meter/metering equipment/service line rentals;

(j) Service charges;

(k) Consumer charges;

(l) Recovery for theft and pilferage of energy;

(m) Rebate availed on account of timely payment of bills;

(n) Miscellaneous receipts;

(o) Deferred Income from grant, subsidy, etc., as per Annual Accounts;

(p) Prior period income, etc.:

Provided that the interest/dividend earned from investments made out of Return on Equity corresponding to
the Retail Supply Business of the Distribution Licensee shall not be included in Non-Tariff Income:

Provided further that any income earned by a Distribution Licensee by sale of power to other Distribution
Licensees or to Consumers as per Section 49 of the Act using the existing power purchase agreements or bulk
supply capacity allocated to the Distribution Licensee’s Area of Supply shall be reduced from the Aggregate
Revenue Requirement of the Distribution Licensee for the purpose of determination of tariff. Such reduction
shall be carried out in accordance with Joint Electricity Regulatory Commission for the State of Goa and
Union Territories (Connectivity and Open Access in Intra-State Transmission and Distribution) Regulations,
2017, as amended from time to time.”

Further, the Regulation 34.2 of the MYT Regulations, 2018 stipulates the following:

“34.2 The delayed payment charge earned by the Transmission Licensee or the Distribution Licensee shall not
be considered under its Non-Tariff Income.”

For FY 2021-22, the Commission has considered the approved Non-Tariff Income (NTI) for FY 2020-21
excluding Delayed Payment Surcharge and Interest on investments and escalated the same by 5%. The same
shall be considered at actuals at the time of truing up.

The NTI approved in the MYT Order, Petitioner’s submission and now approved by the Commission is shown in
the following table:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 135
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Table 116: Non -tariff Income approved by Commission for FY 2021-22 (INR Crore)
Approved in MYT Petitioner's Now Approved
S. No Particulars
Order Submission by Commission
1 Non- Tariff Income 49.60 8.22 12.66

The Commission approves Non-Tariff Income of INR 12.66 Crore in the ARR of the FY 2021-22.

Aggregate Revenue Requirement (ARR)


Petitioner’s submission

Based on the expenses as detailed above, the Petitioner submitted the net aggregate revenue requirement of
INR 3,289.01 Crore after adjusting the Non -Tariff Income for the FY 2021-22.

Commission’s Analysis

On the basis of the detailed analysis of the cost parameters of the ARR the revenue requirement for the FY
2021-22 is approved as provided in the following table:

Table 117: Aggregate Revenue Requirement approved by Commission for FY 2021-22 (INR Crore)
Approved in Petitioner’s Now Approved
S. No Particulars
MYT Order Submission by Commission
1 Power Purchase Cost 3,293.91 3,098.36 3234.13
2 O&M Expense 39.15 48.10 34.78
3 Depreciation 24.98 24.27 21.34
4 Interest Cost on Long-term Capital Loans 10.67 12.08 9.51
5 Interest on Working Capital Loans 53.91 52.59 48.69
6 Return on Equity 24.57 31.42 24.76
7 Provision for Bad Debt 0.00 0.00 0.00
8 Interest on security deposit 2.45 4.20 4.20
9 Income Tax 0.00 26.21 15.00
10 Total 3,449.64 3,297.22 3,392.42
11 Less: Non-Tariff Income 49.6 8.22 12.66
12 Annual Revenue Requirement 3,400.04 3,289.01 3,379.76

The Annual Revenue Requirement approved by the Commission is higher as compared to ARR claimed by the
petitioner mainly due to increase in power purchase cost (Transmission Cost). In Technical Validation Session,
petitioner informed the Commission that they have claimed lower Transmission (PGCIL) charges for FY 2021-
22 in comparison to actual Transmission charges for FY 2019-20 & claimed for FY 2020-21 in expectation that
the charges will decreased after issuing of new Sharing of Inter-State Transmission Charges and Losses
Regulations, 2020. However, the Petitioner further submitted that the actual impact of new CERC Regulation is
very minor than the expected. The Petitioner requested the Commission to reconsider the Transmission
Charges and approved the same as claimed for FY 2020-21. Accordingly, the Commission has approved the
revised transmission charges same as that approved for FY 2020-21 which impacted the total PPC approved for
FY 2021-22.

The Commission approves net ARR of INR 3,379.76 Crore for FY 2021-22.

Revenue at existing Retail Tariff


Petitioner’s submission

The revenue from sale of power at existing tariff is INR 3,570.87 Crore which is based on the projected energy
sales, connected load and number of consumers. The revenue for FY 2021-22 has been computed based on the
retail tariff notified by the Commission in the Tariff Order dated May 18, 2020 for the FY 2020-21.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 136
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

Commission’s Analysis

The category wise/ sub category wise and slab wise revenue at retail tariff is determined as per the applicable
tariff rates. The revenue from demand charges and the energy charges has been projected for each category/
sub category and slab.

The category/ sub category/ slab wise revenue as computed by the Commission for the FY 2021-22 has been
shown in the table below:

Table 118: Revenue at existing tariff computed by Commission for FY 2021-22 (INR Crore)
Fixed
S. Energy charges Total ABR
Category Charges
No (INR Crore) (INR Crore) (INR/unit)
(INR Crore)
1 Domestic 1.03 41.50 42.54 2.54
1 Ist 50 Units 0.13 5.08 5.21 1.54
2 51 to 200 Units 0.26 13.18 13.44 2.24
3 201 to 400 Units 0.15 8.06 8.21 2.80
4 Beyond 401 Units 0.12 15.19 15.31 3.43
5 LIG 0.38 0.38

Commercial/
2
Non Domestic 0.20 16.18 16.38 4.21
1 1st 100 Units 0.13 2.05 2.18 3.40
2 Beyond 100 Units 0.08 14.13 14.20 4.37

3 Agriculture 0.00 0.50 0.50 0.91


1 Upto 10 HP per 0.00
unit 0.30 0.30 0.80
2 Beyond 10 HP per 0.00
unit 0.19 0.19 1.15

4 LT Industry 16.27 104.55 120.82 5.31


Upto 20 HP
1
Connected Load 0.11 2.64 2.75 4.58
Above 20 HP
2
Connected Load 16.16 101.91 118.07 5.33

5 Public Lighting 0.00 1.37 1.37 4.25

Public Water
6
Works 0.44 2.53 2.97 5.64
Upto 20 HP
1
Connected Load 0.33 2.53 2.85 5.42
Above 20 HP
2
Connected Load 0.12 0.00 0.12 -

7 HT Category 640.53 2707.52 3348.05 5.50


1 11 kV 294.61 1186.19 1480.79 5.60
2 66 kV 164.88 775.14 940.01 5.38
3 220 kV 181.05 746.19 927.24 5.45

8 Temporary 0.00 3.07 3.07 8.11

9 Total 658.48 2877.21 3535.69 5.41


*Tariff is 1.5 Times the ABR of Revenue at existing tariff for FY 2021-22

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 137
DNH Power Distribution Corporation Limited
Aggregate Revenue Requirement for FY 2021-22 Joint Electricity Regulatory Commission (JERC)

For FY 2021-22 the Commission has approved INR 3,535.69 Cr for revenue from sale of power which is less
than the revenue claimed (INR 3,570.87 Crore) by the petitioner. The reason for higher revenue claimed by the
petitioner is because of incorrect assumption taken like incorrect billing demand factor while calculating fixed
charge of HT sales, HP to kW factor in calculation for LT sales revenue etc.

The Commission has determined revenue from sale of power at existing tariff as INR 3,535.69
Crore in FY 2021-22.

Standalone Revenue Gap/ Surplus


Petitioner’s submission

Based on the ARR submitted and the revenue from retail tariff, the Petitioner has submitted a standalone
revenue surplus of INR 281.87 Crore for FY 2021-22.

Commission’s Analysis

The Commission based on the approved ARR and revenue at existing retail tariff has derived the following
Revenue Gap/(Surplus):

Table 119: Standalone Revenue Gap/ (Surplus) approved at existing tariff for FY 2021-22 (INR Crore)
Now Approved by
S. No Particulars Petitioner’s submission
Commission
1 Annual Revenue Requirement 3,289.01 3,379.76
2 Revenue from sale of power 3,570.87 3,535.69
3 Revenue Gap/(Surplus) (281.87) (155.94)

The approved standalone revenue surplus at existing retail tariff is INR 155.94 Crore for FY 2021-22 in
comparison to Rs. 281.87 Cr of surplus as claimed by the Petitioner. The reason of this variation is the higher
ARR approved by the Commission which is mainly because of increased Power Purchase Cost. Detail regarding
the same is already provided in Power Purchase Cost/Transmission Charges section.

The estimated surplus is considered while determining the retail tariff for FY 2021-22, as
discussed in the subsequent Chapter.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 138
DNH Power Distribution Corporation Limited
Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

6. Chapter 6: Tariff Principles and


Design

Overall Approach
The Commission while designing retail tariffs for FY 2021-22 has kept in view the principles of determination of
tariff set out in the Electricity Act, 2003 (EA, 2003), Tariff Policy, 2016 and the MYT Regulations, 2018.

The Commission, with this Tariff Order, has tried to meet the objectives of the EA 2003, as set out in its
Preamble, including the protection of the interest of consumers, the supply of electricity to all areas and the
rationalization of tariffs. The EA, 2003 also directs to maintain a healthy balance between the interests of the
utilities and the reasonableness of the cost of power being supplied to consumers. The Commission has also
taken into consideration DNHPDCL’s submissions as well as the Public responses in these proceedings.

The provision of supply of electricity to all the people is an essential driver for development, and influences
social and economic change. Since, the area served by DNHPDCL has 97% of industrial sales, the Commission
has attempted to ensure that, while industries and commerce are promoted, it is not at the cost of other
segments of society while keeping the balance that the subsidising consumer category should not be burdened
beyond a point. The Commission has also tried to ensure regulatory consistency for all stakeholders and
financial sustainability of the Petitioner.

Applicable Regulations
Regulation 19 of MYT Regulations, 2018 states the following:

“19. Annual determination of tariff

19.1 The Commission shall determine the tariff of a Generating Company, Transmission Licensee and
Distribution Licensee covered under a Multi-Year Tariff framework for each Year during the Control Period,
in accordance with timelines specified in Regulation 17, having regard to the following:

a) The approved forecast of Aggregate Revenue Requirement and Expected Revenue from Tariff and Charges
of the Generating Company, Transmission Licensee and Distribution Licensee for such Financial Year,
including modifications approved at the time of Mid-term Review, if any; and

b) Approved gains and losses, including the incentive available, to be passed through in tariff, following the
truing up of previous Year.”

Further, Regulation 67 of MYT Regulations, 2018 states the following:

“67. Determination of Tariff


67.1 The Commission may categorize Consumers on the basis of their load factor, power factor, voltage, total
consumption of electricity during any specified period or the time at which the supply is required or the
geographical position of any area, the nature of supply and the purpose for which the supply is required and
any other factor as considered appropriate by the Commission.
67.2 The Commission shall endeavor to determine cost of supply for each category/ sub-category of
Consumers.
67.3 The Commission shall endeavor to reduce gradually the cross-subsidy between Consumer categories
with respect to the cost of supply in accordance with the provisions of the Act.
67.4 The tariff proposal by Licensee and the tariff determination by the Commission shall be based on the
following principles:
Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

(a) The tariff for all categories shall preferably be two part, consisting of fixed and variable charges.
(b) The fixed charges in tariff shall progressively reflect actual fixed cost incurred by Distribution Licensee;
(c) The overall retail supply tariff for different Consumer categories shall progressively reflect the cost of
supply for respective categories of Consumers;
(d) The tariff for residential Consumers shall be set considering the affordability of tariff for various class of
Consumers;
(e) The tariff shall be set in such a manner that it may not present a tariff shock to any category of
Consumers.”

Cumulative Revenue Gap/ Surplus at Existing Tariff


Petitioner’s Submission

The Petitioner has proposed a cumulative revenue surplus of INR 133.13 Crore at existing tariff for FY 2021-22.
The standalone and consolidated revenue gap/surplus as submitted by the Petitioner has been tabulated below:

Table 120: Cumulative Revenue Gap/ (Surplus) submitted by Petitioner (INR Crore)
S.
Particulars Formulae FY 2019-20 FY 2020-21 FY 2021-22
No.
1 Total ARR 3,646.81 2,861.15 3,289.01
2 Revenue @ Existing Tariff 3,369.82 2,889.11 3,570.87
3 Revenue from Surplus Power Sale 0.00 18.22 0.00
4 Total Revenue 4=2+3 3,369.82 2,907.33 3,570.87
5 Revenue Gap /(Surplus) 5=4-1 276.99 (46.18) (281.87)
Covered By:
Previous year’s Gap/(Surplus) carried
6 (100.14) 180.51 148.11
over
7 Total Gap/(Surplus) 7=5+6 176.85 134.34 (133.75)
8 Holding Cost 3.66 13.77 0.63
9 Net Gap/ (surplus) 9=7+8 180.51 148.11 (133.13)
Reduction in tariff @proposed
10 0.00 0.00 130.52
tariff
11 Net Gap/(Surplus) 11=9+10 180.51 148.11 (2.61)

Commission’s Analysis

Regulation 8.4 of the MYT Regulation, 2014 stipulates the following:

“While approving such expenses/revenue to be adjusted in the future years as arising out of the Review and / or
Truing up exercises, the Commission may allow the carrying costs as determined by the Commission of such
expenses/revenue. Carrying costs shall be limited to the interest rate approved for working capital borrowings."

The Commission observes that the Petitioner has not taken any loan till date. As per the preamble of the
Electricity Act, 2003, the Commission is required to balance the interest of all the stakeholders while
determining the tariff. Keeping in mind all of the above, the Commission has considered the carrying cost @
8.00% which is the opportunity cost for the Petitioner for FY 2018-19. Regulation 11.5 of the MYT Regulation,
2018 stipulates the following:

“11.5 Upon completion of the exercise, the Commission shall pass an order recording:

…..

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 140
DNH Power Distribution Corporation Limited
Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

c) Carrying cost shall be allowed for a Generating Company, Transmission Licensee or Distribution Licensee
on the amount of revenue gap for the period from the date on which such gap has become due, i.e., from the
end of the Year for which true-up has been done, till the end of the Year in which it is addressed, on the basis
of actual rate of loan taken by the Licensee to fund the deficit in revenue:

Provided that carrying cost on the amount of revenue gap shall be allowed subject to prudence check and
submission of documentary evidence for having incurred the carrying cost in the years prior to the year in
which the revenue gap is addressed:

Provided also that if no loan has been taken to fund revenue deficit, the Commission shall allow Carrying Cost
on simple interest basis at one (1) Year State Bank of India (SBI) MCLR /any replacement there of as notified
by RBI for the time being in effect applicable for 1 Year period, as may be, applicable as on 1st April of the
relevant Year plus 100 basis points;

Provided further that in case of revenue surplus, the Commission shall charge the Licensee a Carrying Cost
from the date on which such surplus has become due, i.e., from the end of the Year for which true up has been
done, till the end of the Year in which it is addressed on simple interest basis at one(1) Year State Bank of
India (SBI) MCLR / any replacement thereof as notified by RBI for the time being in effect applicable for 1
Year period, as may be, applicable as on 1st April of the relevant Year plus 100 basis points.”

Since the Petitioner has not borrowed any loan, therefore the Commission allows Carrying Cost on simple
interest basis at one (1) Year State Bank of India (SBI) MCLR, as on 1st April of the relevant FY plus 100 basis
points for FY 2019-20 and FY 2020-21 and 1-yr SBI MCLR as on 10.03.2021 for FY 2021-22.

Accordingly, the Commission determines the standalone revenue gap/surplus for each year and likewise taking
into account the previous year’s gap/surplus, determines the cumulative revenue gap/ surplus at the end of FY
2021-22 as shown in the tables as follows:

Table 121: Standalone Revenue Gap/ (Surplus) determined by Commission at existing tariff (INR Crore)
Particulars FY 2019-20 FY 2020-21 FY 2021-22
Net Revenue Requirement 3614.28 2752.29 3379.76
Revenue from Retail Sales at Existing Tariff 3369.82 2872.78 3,535.69
Revenue from FPPCA - 72.39 0.00
Total Revenue 3,369.82 2,945.17 3,535.69
Standalone Gap/(Surplus) for the year 244.46 (192.88) (155.94)

Table 122: Consolidated Revenue Gap/ (Surplus) determined by Commission at existing tariff (INR Crore)
Particulars FY 2019-20 FY 2020-21 FY 2021-22
Opening Gap/(Surplus) (100.14) 146.43 (42.08)
Addition Gap/(Surplus) of standalone year 244.46 (192.88) (155.94)
Closing Gap/(Surplus) 144.32 (46.45) (198.01)
Average Gap/(Surplus) 22.09 49.99 (120.05)
Rate of Interest 9.55% 8.75% 8.00%
Carrying cost 2.11 4.37 (9.60)
Closing Gap/ (Surplus) 146.43 (42.08) (207.62)

The Commission determines a cumulative revenue surplus of INR 207.62 Crore till FY 2021-22
at existing tariff.

Treatment of the cumulative Gap/Surplus and Tariff Design


As derived above, the resultant consolidated revenue surplus at the end of FY 2021-22 is INR 207.62
Crore, signifies that the existing tariff is excessive as compared to the costs incurred by the Petitioner. In order
to achieve the same, the Commission has decided to reduce the tariff in all of the consumer categories for FY

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 141
DNH Power Distribution Corporation Limited
Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

2021-22. The individual approach adopted and the applicability of the same has been discussed in the following
sections.

6.4.1. Designing of Tariff


Petitioner’s Submission

The Petitioner has proposed to reduce the cumulative surplus of INR 133.13 crore for FY 2021-22 through tariff
reduction in FY 2021-22.
1. The Petitioner proposed to keep the fixed charges of all the consumer categories same as that approved
in the previous Tariff order. Hence the Petitioner has proposed no change in the fixed charges.
2. The Petitioner proposed a reduction in energy charges of consumer categories like Domestic,
Commercial/ Non domestic, LT Industrial, HT Category, agriculture, & public lighting.
3. The Petitioner has also requested the Commission to approve kVAh based tariff for LT Industry which
was earlier billed in kWh.
4. The Petitioner also requested the Commission to approve the fuel purchase adjustment formula
including the “k” factor for FY 2021-22 as well.
The category wise existing and proposed tariff submitted by the Petitioner is as follows:

Table 123: Retail Tariff proposed by Petitioner for FY 2021-22


Existing FY 2020-21 Proposed FY 2021-22
Energy Energy
S.
Category /Consumption Slab Charges Charges
No Fixed Charges Fixed Charges
(INR/ (INR/
kWh) kWh)
1 LT-D/Domestic
10.00 10.00
Ist 50 Units 1.50 1.30
INR./Con/Month INR./Con/Month
10.00 10.00
51 to 200 Units 2.20 2.00
INR./Con/Month INR./Con/Month
10.00 10.00
201 to 400 Units 2.75 2.55
INR./Con/Month INR./Con/Month
10.00 10.00
Beyond 401 Units 3.40 3.20
INR./Con/Month INR./Con/Month
20.00 20.00
LIG
INR./Con/month INR./Con/month
LT-C/Commercial/Non
2
Domestic
20.00 20.00
1st 100 Units 3.20 3.00
INR./Con/Month INR./Con/Month
20.00 20.00
Beyond 100 Units 4.35 4.15
INR./Con/Month INR./Con/Month
3 LT- Ag/ Agriculture
Upto 10 HP per unit 0.80 0.60
Beyond 10 HP per unit 1.15 0.95
4 LTP Industrial
20.00 20.00
Upto 20 HP Connected Load 4.40 4.20/kVAh
INR./HP/month INR./HP/month
80.00 80.00
Above 20 HP Connected Load 4.60 4.40/kVAh
INR./HP/month INR./HP/month
5 LT-PL/Public Lighting
Public Lighting 4.25 4.05
6 LT Public Water Works
50.00 50.00
Upto 20 HP Connected Load 4.80 4.60
INR./HP/month INR./HP/month
100.00 100.00
Above 20 HP Connected Load 4.80 4.60
INR./HP/month INR./HP/month

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 142
DNH Power Distribution Corporation Limited
Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

Existing FY 2020-21 Proposed FY 2021-22


Energy Energy
S.
Category /Consumption Slab Charges Charges
No Fixed Charges Fixed Charges
(INR/ (INR/
kWh) kWh)
7 HT
HT Category
4.40 INR 400.00 4.20 INR 400.00
11 kV
/kVAh INR./kVA/month /kVAh INR./kVA/month
4.35 INR 525.00 4.15 INR 525.00
66 kV
/kVAh INR./kVA/month /kVAh INR./kVA/month
4.30
575.0 4.10 575.0
220 kV INR/kVA
INR/kVA/month INR/kVAh INR/kVA/month
h
8 Hoardings/Advertisements
100.00 100.00
For all units 7.55 7.35
INR./kVA/month INR./kVA/month
Charging Stations for e-
9 rickshaw/e-vehicle on single 4.80 - 4.60 -
point delivery

Commission’s Analysis

As discussed above, the Commission has determined the retail tariff for FY 2021-22 in accordance with the
principles stated in the Electricity Act, 2003, Tariff Policy, 2016, and the MYT Regulations, 2018. The Tariff
design in general is guided by the following principles:

1. Cost reflective: The tariffs determined should efficiently reflect the cost of supply for each
consumer category.
2. Progressive tariffs: Ensuring progressivity among tariffs by having telescopic tariff slabs which
encourages efficient consumption and at the same time promotes intra-category cross-subsidy by
way of charging higher tariff for higher consumption to subsidize the lower consumption
consumers.
3. Revenue neutrality: There should be no impact on the utility’s yearly revenue due to rationalization
of tariffs i.e. the overall status quo should be maintained.
4. Revenue stability: Utilities should ensure adequate fixed cost recovery from fixed/demand charges.
5. Demand management and grid stability: Demand management and grid stability should be ensured
with demand-based tariffs.
6. Simplified tariff structure: Tariff structure should be simplified to make it easily administrable by
the utility and easy to understand for the consumer.
7. Smart tariff design: Tariff rate design should take into consideration trends in electric power such
as small scale renewable generation by consumers, energy efficiency, electric vehicle charging, etc.

While all the above parameters contribute significantly in developing a sustainable tariff framework, there are
certain parameters namely Cost of Supply and Tariff Affordability, which are of importance and constitute the
building blocks in achieving the overall objective. The context and the approach for these parameters have been
discussed as follows:

1. Cost of Supply

a) Context

Due to electricity being a crucial utility item for all consumers, over the period of time, various socio-
economic issues have been factored in to determine the end user’s tariffs. This has unfortunately led to

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Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

severe imbalance between the tariffs levied vis-a-vis the cost of supply of the electricity, causing distress to
the Discom. For example, in order to ensure that tariffs are kept in check for residential consumers, while
still allowing cost recovery for Discoms, cross subsidy is built in between categories. The tariffs so
determined, are skewed, with tariff for industrial and commercial consumers being higher and for other
categories being lower than their respective costs of supply. The implications of this imbalance in tariffs is
twofold – jeopardizing the competitiveness of industries owing to higher input costs and inability of
Discoms to recover sufficient tariffs from domestic consumers, resulting in financial distress. The issue is
more pronounced for rural supply where tariffs are highly subsidized, actual cost of supply is higher and
revenue recovery is poor.

It is thus essential that tariffs reflect the true cost to service a category of consumer. As a crucial first step
towards cost-reflective tariffs, it is important for distribution utilities to determine the costs of supply
(which cascade from generation to transmission and finally to distribution and retail supply of power) that
should be prudently recovered from each consumer category. These costs should correspond to the actual
costs being imposed by each consumer category on the Discom. By determining consumer category wise
costs of supply, the Discom would be in a better position to allocate costs where relevant and determine
how tariffs can be levied fairly on each category.

The overall approach that can be followed for accurately determining the Cost of Supply has been
discussed as follows:

b) Approach:

Presently, the most commonly used approach for determining the cost of supply of electricity for tariff
determination is the Average Cost of Supply method. The ACoS is computed by dividing the Annual
Revenue Requirement (ARR) determined by the Commission for recovery through tariffs by the total
energy sales for the year. However, this methodology does not indicate the costs incurred by consumers at
different voltage levels using different assets of the network. Therefore, it does not help in determining
accurate tariffs for particular consumers, eventually resulting in insufficient cost coverage.

As a next logical step, the Voltage wise cost of supply (VCoS) method provides a better reflection of cost to
supply to consumers at different voltage levels. A simplified version of the same was suggested by ATE in
2010, to determine VCoS in the absence of all necessary data. In this method, the power purchase costs
and other costs (such as network costs, wheeling costs etc.) are allocated to various consumer categories
based on energy input or energy sales (as considered appropriate by the State Commission). This approach
factors in the voltage level differentiation based on losses, however, it does not factor in asset utilization at
different voltage levels.

A more refined version of determination of VCoS uses three parameters for allocating various costs to
voltage levels – energy input at each voltage level, energy sales and asset allocation to voltage levels. The
losses segregated voltage wise (as percentage of input energy) are to be allocated to different voltage levels
based on energy input to each voltage level (as explained in subsequent sections). Subsequently, the cost
elements such as power procurement costs, employee expenses, administrative and general expenses and
income tax can be allocated to each voltage levels based on total sales at each voltage level. The cost
elements, which are dependent on assets such as depreciation, interest costs, return allowed to utility etc.
are allocated in ratio of assets allocated to each voltage level. The sum of all the cost components at each
voltage level is the cost to supply the particular voltage (EHT/HT/LT).

The Commission is of the opinion that while VCoS differentiates cost allocation based on voltage levels, it
does not factor in consumer category level differentiation. For instance, at the same LT level, cost of
supplying electricity to a Commercial consumer may be different from that of a Residential consumer.
Thus, it believes that the most progressive way forward for DNHPDCL is to accurately determine the cost
of supply is to attempt to determine Cost of Supply at category level. The Commission notes that states like
Andhra Pradesh and Telangana have determined Category wise Cost of Supply albeit with several
assumptions and DNHPDCL must also attempt to determine the same.

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On studying the existing methodologies followed internationally, among developing nations with energy
access situations like India’s, the Commission is of the opinion that the Category wise Cost of Supply
methodology is an appropriate starting point. The embedded cost method identifies and appropriately
assigns the historical or accounting costs that make up a Discom’s revenue requirement to all categories
and sub-categories of consumers.

This method involves three steps:

• Cost Functionalization

• Cost Classification

• Cost Allocation

Cost functionalization separates cost data into the functional activities performed in the operation of a
utility system - power generation/supply, transmission, distribution and retail supply. Classification
determines the portion of the cost that is related to specific cost-causal factors, such as those that are
demand-related, energy-related, or customer-related. Finally, the cost allocation step assigns the costs to
specific customer categories based on the customer’s contribution to the specific classifier selected.

The Commission as part of this Order has determined the tariff according to the Average Cost of Supply
(ACoS) due to lack of requisite data. The Commission strongly believes that determination of Category
wise Cost of Supply is essential to ensure cost reflectivity in tariffs fixed for different categories. However,
the Commission feels that to carry out this exercise a lot of field level information would be required such
as Category wise co-incident and non- co-incident demand, Voltage wise value of assets (Voltage wise asset
ratio), Voltage wise losses, Category wise break-up of costs related to Metering, Billing and Collection etc.
which currently the Petitioner doesn’t maintain. Therefore, in absence of the same the Commission is
unable to determine the Category wise CoS in this Order but directs the Petitioner to start
maintaining this data and submit the same in the tariff proceedings of next year.

2. Tariff Affordability

a) Context

The Commission understands that the consumer base of DNHPDCL is varied and covers a wide spectrum
of socio-economic backgrounds, specially the domestic category consumers. It is aware that most low
income households spend a substantial share of their income on utility services such as electricity, heating
and water. However, any envisaged tariff reform is often objected to avoid further burdening of these
consumers. But to improve the quality of service of electricity, the Discom has to undergo significant
capital expenditure which eventually deteriorates the affordability of tariffs. Thus, to tackle this problem
and in the spirit of economic wellbeing of all consumer classes, the concept of cross-subsidies has been
built into the current tariff structure.

However, the Commission believes that a more scientific and logical approach can be adopted to identify
the right categories of consumers and the right cross-subsidy/subsidy requirement that will benefit the
end consumers at the same time. Hence, the Commission believes that there is a strong need to develop a
scientific methodology to assess the social impact of electricity tariffs.

The overall approach that can be followed for determining the tariff affordability has been discussed as
follows.

b) Approach

On reviewing methodologies adopted globally for social impact assessment of electricity tariffs by studying
international research reports and studying model practices internationally, the Commission found that
Tariff Affordability Ratio (TAR) is a reliable parameter to measure affordability of electricity in
households.

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Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

TAR is defined by obtaining the burden incurred by a household for electricity as compared to the overall
household expenditure. The rationale behind this concept is that the electricity is basic utility and is
unavoidable in today’s scenario, however, this does not ensure that the expenditure level is in line with the
overall household expenditure. Hence, this concept helps to understand the affordability level of electricity
on households with different economic levels.

The electricity expenditure can be determined initially for domestic consumers by computing the average
consumption levels across each slab and the household expenditure can be estimated from national
surveys of household expenditure across economic levels conducted by organizations like NSSO.
Thereafter the distribution of consumers of the Discom across tariff slabs can be mapped across the
established economic levels to develop the final affordability ratio matrix for the Discom’s domestic
consumer base.

Following the identification of the current ratio of Tariff Affordability, the Commission in consultation
with the stakeholder’s will develop benchmarks for acceptable affordability levels by studying trends
across countries with a demography and energy scenario similar to that of India and propose appropriate
tariffs. The final output shall help understand the Commission to modify tariffs in cases where there is
more room for tariff increase or a need to correct tariffs. The exercise would also help the Commission in
setting tariff slabs as per the paying capacity of the consumers, which would be beneficial especially for
Domestic category consumers. Additionally, this shall also help the Government to formulate better
schemes to effectively channelize its intended benefits.

The Commission in these tariff proceedings is not carrying out this exercise due to unavailability of
accurate data. The Petitioner is directed to ensure the sanctity of the data maintained pertaining to various
categories.

Keeping in view the above principles, the Commission has made the following amendment in the retail
tariff applicable for FY 2021-22:

1. On account of the projected cumulative revenue surplus during FY 2021-22 at existing tariff, the
Commission has decided to reduce the tariff. The energy charge of all consumer categories has been
reduced.

2. The fixed charge has not been altered for any of the categories for FY 2021-22.

3. For LT Industrial categories, the Commission has modified the Energy Charge, earlier payable on kWh
basis to kVAh basis now.

6.4.2. Approved Final Tariff Schedule


6.4.2.1. Approval of kVAh based billing for LT Industrial Consumers

As per the submission of the Petitioner, the Commission in this Tariff Order has approved kVAh based tariff for
LT Industries. In this regard the Commission would like to emphasize that the kVAh based billing has an inbuilt
incentive/penalty mechanism and therefore separate mechanism for the PF incentive/penalty is no more
required. It encourages the consumers to improve the power factor by way of reactive power compensation at
the load point itself. Further, with better power factor, the line loading shall be lower for the same kW
requirement and it helps in improving power supply quality.

6.4.2.2. Existing and retail Tariff for FY 2021-22

The existing retail tariff and revised tariff now approved by the Commission for each consumer category has
been shown in the following table:

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Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

Table 124: Existing and Approved Tariff for FY 2021-22


Existing for FY 2020-21 Approved for FY 2021-22
S.
Category Energy Energy
No. Fixed Charges Fixed Charges
Charges Charges
1 LT-D/Domestic
(i) 0-50 Units 1.50 INR/ kWh 1.40 INR/ kWh
(ii) 51 to 200 Units 10.00 INR/ Con/ 2.20 INR/kWh 10.00 INR/ Con/ 2.10 INR/kWh
(iii) 201 to 400 Units Month 2.75 INR/ kWh Month 2.60 INR/ kWh
(iv) Beyond 401 Units 3.40 INR/kWh 3.20 INR/kWh
20.00 INR/ Con/ 20.00 INR/ Con/
(v) LIG - -
Month Month
2 LT-Non Domestic/Commercial
(i) 0 - 100 Units 20.00 INR/ Con/ 3.20 INR/kWh 20.00 INR/ Con/ 3.10 INR/kWh
(ii) Beyond 100 Units Month 4.35 INR/ kWh Month 4.10 INR/ kWh
3 LT- Ag/ Agriculture and Poultry
(i) Upto 10 HP 0.80 INR/kWh 0.75 INR/kWh
(ii) Beyond 10 HP 1.15 INR/ kWh 1.10 INR/ kWh
4 LTP Industrial
(a) LTP Motive Power
Upto 20 HP Connected 20.00 20.00
(i) 4.40 INR/kWh 3.50 INR/kVAh
Load INR/HP/month INR/HP/month
Above 20 HP Connected 80.00 80.00
(ii) 4.60 INR/kWh 3.70 INR/kVAh
Load INR/HP/month INR/HP/month
(b) LT Public Water Works
Upto 20 HP Connected 50.00 50.00
(i) 4.80 INR/kWh 4.60 INR/kWh
Load INR/HP/Month INR/HP/Month
Above 20 HP Connected 100.00 100.00
(ii) 4.80 INR/kWh 4.60 INR/kWh
Load INR/HP/Month INR/HP/Month
5 LT-PL/Public Lighting
Public Lighting - 4.25 INR/kWh - 4.05 INR/kWh
6 HT INDUSTRIAL
400.00 4.40 INR/ 400.00 4.10 INR/
(i) 11 kV
INR/kVA/month kVAh INR/kVA/month kVAh
525.00 4.35 INR/ 525.00 4.05 INR/
(ii) 66 kV
INR/kVA/month kVAh INR/kVA/month kVAh
575.00 4.30 INR/ 575.00 4.00 INR/
(iii) 220 kV
INR/kVA/month kVAh INR/kVA/month kVAh
7 Hoardings/Advertisements
100.00 100.00
For all units 7.55 INR/kWh 7.30 INR/kWh
INR/kVA/month INR/kVA/month
Charging Stations for
e-rickshaw/e-vehicle
8 - 4.80 INR/kWh - 4.70 INR/kWh
on single point
delivery

6.4.3. Revenue from Approved Retail Tariff for FY 2021-22


Based on the retail approved tariff as shown above, the revenue from approved tariff is shown in the following
table. The Commission has not estimated any revenue for Electric Vehicle (EV) Charging Station and Hoarding
/ Advertisements category due to unavailability of requisite data. The Commission as of now approves the k
factor for these two categories as shown in the following table, however, directs the Petitioner to submit
the requisite data for energy sales, no. of consumers and connected load in case any consumers
are identified under these two categories. Further, due to unavailability of EV charging station as on

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Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

date, k-Factor of 1.00 is considered for the same. The revenue from approved Retail Tariff for FY 2021-22 is
shown in the Table below:

Table 125: Revenue from Approved Retail Tariff for FY 2021-22


Fixed Energy ABR
S. Total k-
Category Charges charges (INR/
No (INR Cr) factor
(INR Cr) (INR Cr) unit)
1 DOMESTIC 1.03 39.23 40.27 2.40 0.47
(i) 0-50 units 0.13 4.74 4.87 1.44 0.28
(ii) 51-200 units 0.26 12.58 12.84 2.14 0.42
(iii) 201-400 units 0.15 7.62 7.77 2.65 0.52
(iv) 401 and above 0.12 14.29 14.41 3.23 0.63
(v) Low Income Group (LIG) 0.38 0.00 0.38

2 COMMERCIAL/Non-Domestic 0.20 15.30 15.51 3.99 0.78


(i) 0-100 units 0.13 1.99 2.11 3.30 0.65
(ii) 101 Units and Above 0.08 13.32 13.39 4.12 0.81

3 LT INDUSTRIAL
(i) LTP Motive Power (For All Units) 16.27 98.84 115.12 5.06 0.99
Up to 20 HP 0.11 2.47 2.58 4.30 0.84
Above 20 HP 16.16 96.37 112.53 5.08 0.99
LT Public Water Works (For all
(ii)
units) 0.44 2.42 2.86 5.44 1.07
Up to 20 HP 0.33 2.42 2.75 5.22 1.02
Above 20 HP 0.12 0.00 0.12 - -

4 HT/EHT INDUSTRIAL 640.53 2521.12 3161.65 5.19 1.02


(i) 11 kV 294.61 1105.31 1399.92 5.30 1.04
(ii) 66 kV 164.88 721.68 886.56 5.08 0.99
(iii) 220 kV 181.05 694.13 875.18 5.15 1.01

5 AGRICULTURE AND POULTRY 0.00 0.47 0.47 0.86 0.17


(i) For sanctioned load upto 10 HP 0.00 0.28 0.28 0.75 0.15
(ii) Beyond 10 HP 0.00 0.18 0.18 1.10 0.22

6 PUBLIC LIGHTING 0.00 1.30 1.30 4.05 0.79

7 HOARDINGS/SIGNBOARDS 0.00 0.00 0.00 - -

8 TEMPORARY* 0.00 2.90 2.90 7.66 1.50

9 EV CHARGING STATION 0.00 0.00 0.00 - -

Total 658.48 2681.60 3340.08 5.11 1.00


*Tariff will be 1.5 Times the ABR of relevant category for FY 2021-22

The Commission approves revenue from approved Retail Tariff of INR 3,340.08 Crore for the
FY 2021-22.

The following table provides the category wise Average Cost of Supply (ACoS), Existing Average Billing Rate
(ABR), Approved ABR and the change in tariff for each of the consumer categories.

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Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

Table 126: Tariff increase/decrease approved by Commission for FY 2021-22


ACOS ABR at ABR at approved
S. Decrease in
Category (INR existing tariff tariff
No ABR (%)
/kwh) (INR /kwh) (INR /kwh)
1 Domestic 5.17 2.54 2.40 -5.34%
2 LT Commercial 5.17 4.21 3.99 -5.35%
3 Agriculture 5.17 0.91 0.86 -5.51%
4 LT Industrial 5.17 5.31 5.06 -4.72%
5 Public Lighting 5.17 4.25 4.05 -4.71%
6 Public Water Works 5.17 5.64 5.44 -3.55%
7 HT Industrial 5.17 5.50 5.19 -5.57%
8 Temporary 5.17 8.11 7.66 -5.53%
9 Total 5.17 5.41 5.11 -5.53%

The average reduction in the retail tariff now approved by the Commission vis-à-vis tariff
approved for FY 2020-21 vide Order dated May 18, 2020 is 5.53%.

6.4.4. Revenue Gap/ Surplus at Approved Tariff


On considering the revenue at approved tariffs, the resultant cumulative Revenue Gap/(Surplus) has been
shown in the table below:

Table 127: Cumulative revenue Gap/ (Surplus) at approved Tariff for FY 2021-22
S.
Particulars Formulae FY 2019-20 FY 2020-21 FY 2021-22
No.
a Net Revenue Requirement 3,614.28 2,752.29 3,379.76
Revenue from Retail Sales at
b 3369.82 2,872.78 3,340.08
Proposed Tariff
Revenue from FPPCA
c - 72.39 0.00
Charges
d Total Revenue (d=b+c) 3369.3,369.82 2,945.17 3,340.08
Standalone Gap/
e (e=a-d) 244.46 (192.88) 39.68
(Surplus) for the year
f Opening Gap/ (Surplus) (100.14) 146.43 (42.08)
g Closing Gap/ (Surplus) (g=e+f) 144.32 (46.45) (2.40)
h Average Gap/ (Surplus) h=(g+f)/2 22.09 49.99 (22.24)
i Rate of Interest 9.55% 8.75% 8.00%
j Carrying cost j=i*h 2.11 4.37 (1.78)
k Closing Gap/ (Surplus) k=g+j 146.43 (42.08) (4.18)

After reduction in Tariff by 5.53%, the Commission approves a cumulative revenue surplus of
INR 4.18 Crore till FY 2021-22. The Commission has designed the category-wise tariffs to almost
match the Revenue at approved (reduced) tariff to meet the ARR for FY 2021-22 including
cumulative revenue surplus. The approved cumulative closing surplus of INR 4.18 Crore is only
0.1% of the approved ARR for FY 2021-22 which may get adjusted due to variation in actual sales
mix during the year.

6.4.5. Highlights of the Tariff Structure


The highlights of the tariff structure approved by the Commission for FY 2021-22 are as follows:

1. On account of the projected cumulative revenue surplus during FY 2021-22 at existing tariff, the
Commission has decided to reduce the tariff. The energy charge of all consumer categories has been
reduced.

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Tariff Principles and Design Joint Electricity Regulatory Commission (JERC)

2. The fixed charge has not been altered for any categories.

3. For LT Industrial categories, the Commission has modified the Energy Charge, payable earlier on kWh
basis to kVAh basis now.

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Open Access Charges Joint Electricity Regulatory Commission (JERC)

7. Chapter 7 Open Access Charges for


the FY 2021-22

Determination of Additional Surcharge


Petitioner’s submission:

The Petitioner has submitted the following calculations for Additional Surcharge for FY 2021-22:

Table 128: Additional Surcharge submitted by Petitioner for FY 2021-22


Particulars Value
Total Power Purchase cost (INR Crores) 3098.36
Fixed Cost component in Power Purchase Cost (including Transmission Charges)
1272.19
(INR Crores)
Energy Sales (MU) 6540.77
Additional Surcharge (INR/kWh) 1.95

Commission’s Analysis

The Commission has notified the Joint Electricity Regulatory Commission for the State of Goa and Union
Territories (Connectivity and Open Access in Intra-State Transmission and Distribution) Regulations, 2017.
Regulation 4.5 (1) of the said Regulations states the following:

“4.5 Additional Surcharge

1. 1. An Open Access Consumer, receiving supply of electricity from a person other than the Distribution
Licensee of his area of supply, shall pay to the Distribution Licensee an additional surcharge in
addition to wheeling charges and cross-subsidy surcharge, to meet the fixed cost of such Distribution
Licensee arising out of his obligation to supply as provided under sub-section (4) of Section 42 of the
Act”

2. This additional surcharge shall become applicable only if the obligation of the Licensee in terms of
power purchase commitments has been and continues to be stranded or there is an unavoidable
obligation and incidence to bear fixed costs by the Licensee consequent to such a contract. However,
the fixed costs related to network assets would be recovered through wheeling charges.

……”

Further, Regulation 5.2 of the aforesaid JERC Regulations states the following:

“5.2 Imbalance Charges

1. Settlement of Energy at Drawal Point in Respect of Open Access Consumer, or Trading


Licensee on Behalf of Open Access Consumer

…….

b. Open Access Consumer, who is also a Consumer of the Distribution Licensee

……

The quantum of drawal of electricity by a partial Open Access Consumer from the Distribution Licensee
during any Time Block of a Day should not exceed the “Admissible Drawl of Electricity by the Open Access
Open Access Charges Joint Electricity Regulatory Commission (JERC)

Consumer” which is the difference of Contract Demand and maximum quantum of Open Access for which
approval has been granted by the Nodal Agency.

[Illustration: If an Open Access Consumer with a Contract Demand of 10 MW has been given an approval for
a maximum Open Access quantum of 6MW for a period of 3 Months, the Admissible Drawl of Electricity from
the Distribution Licensee during any Time Block shall be 4 MW for any Day during a period of 3 Months.]”

Therefore, in accordance with the above Regulations, the Commission has determined the Additional Surcharge
as per the following:

Table 129: Additional Surcharge approved by Commission for FY 2021-22


S. No. Particulars Value
Total Power Purchase Fixed Cost approved for (excluding transmission
1 934.25
charges) (INR Crores)
2 Energy Sales (MUs) 6540.77
3 Additional Surcharge (INR/kWh) 1.43

As per the Joint Electricity Regulatory Commission for the State of Goa and Union Territories (Open Access in
Transmission and Distribution) Regulations, 2009, which is repealed now, a consumer availing Open Access
was required to pay full fixed charges on contracted load even when the load was drawn partially from the
Distribution Licensee. However, as per the “JERC (Connectivity and Open Access in Intra-State
Transmission and Distribution) Regulations, 2017, a consumer is now required to pay fixed
charges on reduced demand after adjusting for demand drawn through Open Access in
accordance with the Regulations.

The Commission approves an Additional Surcharge of INR 1.43/kWh for FY 2021-22.

The Commission directs the Petitioner to submit quarterly details of power stranded on account
of consumers opting for open access along with the Additional Surcharge recovered from these
consumers. The Commission will analyze the information and revise the applicable Additional Surcharge, if
required.

Determination of Wheeling Charges


7.2.1. Allocation Matrix - Allocation of ARR into Wheeling and
Retail Supply of Electricity
Petitioner’s submission:

The Petitioner has submitted the allocation of ARR into wheeling and retail supply of electricity as shown in the
table below.

Table 130: Allocation of ARR between Wheeling and Retail Supply as submitted by Petitioner for FY 2021-22
Annual Revenue Requirement Allocation (%) Allocation FY 2019-20
Particular Wheeling Supply Wheeling Supply
Fuel Cost 0% 100% 0 0
Power Purchase Cost 0% 100% - 3,098.36
Employee 40% 60% 5.75 8.63
R&M 90% 10% 23.05 2.56
A&G 50% 50% 4.06 4.06
Depreciation 90% 10% 21.85 2.43
Interest Cost on Long-term Capital Loans 90% 10% 10.87 1.21
Interest on Working Capital Loans 10% 90% 5.26 47.33
Interest on Security Deposit 10% 90% 0.42 3.78
Return on Equity 90% 10% 28.28 3.14

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Annual Revenue Requirement Allocation (%) Allocation FY 2019-20


Particular Wheeling Supply Wheeling Supply
Income Tax 90% 10% 23.58 2.62
Provision for Bad and Doubtful Debt 0% 100% - -
Annual Revenue Requirement 123.11 3174.11
Less: Non-Tariff Income 10% 90% 0.82 7.40
Less: Revenue from Surplus Power Sale 50% 50% - -
Net Revenue Requirement 122.29 3166.72

In order to determine the wheeling charges the Petitioner has allocated the wheeling cost on the basis of voltage
levels. The criteria for allocation of wheeling costs are elaborated as follows:

• O&M Expenses are allocated on the basis of number of consumers under each category.

• All expenses other than the O&M expenses are allocated on the basis of voltage wise asset allocation.

The voltage wise asset allocation assumed and the number of consumers in each category as submitted by the
Petitioner is shown in table below:

Table 131: Parameters assumed by Petitioner for voltage wise allocation of wheeling charges
Asset Energy
Consumers Sales Voltage wise
Category Allocation Input
(nos.) (MU) losses (%)
(%) (MU)
Below 11 kV-LT 83983 452.64 40% 23.42% 590.32
11 kV 934 2,641.96 30% 3.80% 2746.32
66 kV 32 1746.29 20% 1.50% 1772.88
220 kV 2 1700.62 10% 0.60% 1710.88
Total 84951 6,541.51 100% 4.10% 6,820.41

The wheeling charges submitted by the Petitioner are as below:

Table 132: Wheeling charges proposed by Petitioner for FY 2021-22


Wheeling
O&M Others Total
Category Charges
(INR Crore) (INR Crore) (INR Crore)
(INR/kWh)
Below 11 kV-LT 32.48 35.77 68.26 1.16
11 kV 0.36 26.83 27.19 0.10
66 kV 0.01 17.89 17.90 0.10
220 kV 0.00 8.94 8.94 0.05
Total 32.86 89.44 122.29

Commission’s Analysis:

In this regard, the Regulations 48 of the JERC MYT Regulations, 2018 specifies as follows:

“48. Separation of Accounts of Distribution License

48.1 Every Distribution Licensee shall segregate accounts for Distribution Wires Business and Retail Supply
Business and shall prepare an Allocation Statement. The wheeling charges pertaining to Distribution Wires
Business of the Distribution Licensee shall be determined by the Commission on the basis of these segregated
accounts:

Provided that in case complete accounting segregation has not been done, the following Allocation Statement
shall be applicable…..”

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 153
DNH Power Distribution Corporation Limited
Open Access Charges Joint Electricity Regulatory Commission (JERC)

The Commission as per the MYT Regulations, 2018 has calculated the wheeling charges while taking into
consideration the allocation matrix and the ARR approved in the Tariff order for FY 2020-21. The allocation
between wheeling and retail supply business for FY 2021-22 as per the ARR approved in this Order is provided
in the table as follows:

Table 133: Allocation matrix approved by Commission for FY 2020-21


Allocation (%) Values
Particulars
Wheeling Supply Wheeling Supply Total
Cost of power purchase for full
0% 100% 0.00 3234.13 3234.13
year
Employee costs 40% 60% 5.89 8.84 14.73
Administration and General
50% 50% 3.49 3.49 6.97
Expenses
Repair and Maintenance Expenses 90% 10% 11.77 1.31 13.07
Depreciation 90% 10% 19.21 2.13 21.34
Interest and Finance charges 90% 10% 8.56 0.95 9.51
Interest on Working Capital 10% 90% 4.87 43.82 48.69
Interest on consumer security
10% 90% 0.42 3.78 4.20
deposit
Return on Equity 22.21 2.55 24.76
Provision of Bad & Doubtful Debt 0% 100% 0.00 0.00 0.00
Income Tax 90% 10% 13.50 1.50 15.00
Total Revenue Requirement 89.92 3302.50 3392.42
Less: Non-Tariff Income 10% 90% 1.27 11.39 12.66
Income from other Business 50% 50% 0.00 0.00 0.00
Net Revenue Requirement 88.65 3291.11 3379.76

In order to determine the wheeling charges prudently, the Commission has allocated the wheeling costs on the
basis of voltage levels. The wheeling charges are levied for the distribution network utilized by Open Access
consumers and primarily comprise of O&M Expenses and other costs as provided in the table above. The
criteria for allocation of wheeling costs are elaborated as follows:

• O&M Expenses are allocated on the basis of number of consumers under each category
• All expenses other than the O&M expenses are allocated on the basis of voltage wise asset allocation.
The same has been considered based on Petitioner’s submission in this regard.
The Commission had issued directive in Tariff Order dated April 7, 2016, to the Petitioner regarding actual
voltage wise expenses and assets allocation which has not been made available. Since the actual Voltage wise
allocation of expenses and asset allocation for all voltages are not yet available, it is being assumed.
The voltage wise asset allocation assumed and the number of consumers in each category has been shown as
follows:

Table 134: Parameters assumed for voltage wise allocation of wheeling charges
Voltage
Energy
Energy Sales Line Loss Wise Asset
Particulars Input Consumers
(MU) (%) Allocation
(MU)
(%)
Below 11kV 451.90 23.45% 590.32 83983 40%
11kV 2641.96 3.80% 2746.32 936 30%
66kV 1746.29 1.50% 1772.88 29 20%
220 kV 1700.62 0.60% 1710.89 3 10%
Total 6540.77 4.10% 6820.41 84951 100%

Accordingly, the Commission approves the Wheeling Charges as follows:

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 154
DNH Power Distribution Corporation Limited
Open Access Charges Joint Electricity Regulatory Commission (JERC)

Table 135: Wheeling Charges approved by Commission for FY 2021-22


O&M Others Total Wheeling Charges
Category
(INR Crore) (INR Crore) (INR Crore) (INR/kWh)
Below 11kV 20.90 27.00 47.91 1.06
11kV 0.23 20.25 20.48 0.08
66kV 0.01 13.50 13.51 0.08
220 kV 0.00 6.75 6.75 0.04
Total 21.14 67.50 88.65

The Commission approves wheeling charge of INR 1.06/kWh at LT voltage level, INR 0.08/kWh
at 11 kV, INR 0.08/kWh at 66 kV voltage level and INR 0.04/kWh at 220kV for FY 2021-22.

Cross-Subsidy Surcharge
Petitioner’s Submission:

The Petitioner has determined the cross subsidy charges on the basis of voltage wise cost of supply. Voltage
Wise losses at each voltage level are assumed for 11 kV, 66 kV and 220 kV voltage levels. The remaining losses
are adjusted in the LT voltage level in order to maintain the Distribution losses at 4.10%, as proposed in the
ARR for FY 2021-22
Table 136: Cross-subsidy Surcharge for FY 2021-22 submitted by Petitioner
VCoS Cross-Subsidy
Category ABR (INR/kWh)
(INR/kWh) (INR/kWh)
Below 11 kV-LT 8.25 4.09 -4.16
11 kV 4.89 5.66 0.77
66 kV 4.78 5.34 0.56
220 kV 4.65 5.40 0.75

Commission’s Analysis

The Commission in this Order has calculated the cross-subsidy surcharge with respect to voltage wise cost of
supply. The following approach has been adopted to determine the voltage wise cost of supply:

• Voltage Wise losses at each voltage level are assumed for 11kV, 66kV & 220 kV voltage categories. The
remaining losses are adjusted in the LT voltage level in order to maintain the Intra-State T&D losses at
4.10%, as approved in the ARR for FY 2021-22. Voltage wise losses assumed at each level have been shown
in the table below:

Table 137: Voltage Wise Losses considered by the Commission


Voltage Level Loss Cumulative Losses upto
Category
(%) that voltage level (%)
Below 11kV 23.45% 23.45%
11kV 3.80% 5.90%
66kV 1.50% 2.10%
220 kV 0.60% 0.60%
Total 4.10% 4.10%
Using these losses, the energy input at each voltage level is determined based on the energy sales. The table
below shows the energy input at each voltage level:

Table 138: Energy Input at each voltage level (MU)


Energy Sales Cumulative Energy Input
Category
(MU) Losses (%) (MU)
Below 11kV 451.90 23.45% 590.32
11kV 2641.96 5.90% 2746.32

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 155
DNH Power Distribution Corporation Limited
Open Access Charges Joint Electricity Regulatory Commission (JERC)

Energy Sales Cumulative Energy Input


Category
(MU) Losses (%) (MU)
66kV 1746.29 2.10% 1772.88
220 kV 1700.62 0.60% 1710.89
Total 6540.77 4.10% 6820.41

Now the overall ARR approved for FY 2021-22 is divided into variable and fixed ARR with variable ARR
comprising of variable component of power purchase cost and fixed ARR comprising of all the other costs.
The fixed component comprising of fixed cost of power purchase, O&M etc. is further allocated to each voltage
category as per the following principles:
• The fixed cost of power purchase is assigned to each voltage level on the basis of energy input at
respective voltage levels.

• The O&M expenses are allocated to each voltage level on the basis of the number of consumers. The
resultant cost allocated to 220 kV level is then further allocated to 66 kV, 11 kV & LT level on the basis of
input energy, as the 220 kV network is utilized by remaining network consumers. Similarly, 66 kV and 11
kV costs are allocated to the lower levels following the same approach.
• The remaining fixed costs are allocated on the basis of voltage wise asset allocation assumed earlier and
further allocated to respective voltage levels on the basis of input energy.

Table 139: Parameters used for allocation of fixed costs


Energy Input Number of Voltage wise Asset
Category
(MU) Consumers Allocation (%)
Below 11kV 590.32 83983 40.00%
11kV 2746.32 936 30.00%
66kV 1772.88 29 20.00%
220 kV 1710.89 3 10.00%
Total 6820.41 84951 100.00%
The variable component of the Power purchase cost is allocated on the basis of energy input. The Voltage wise
Cost of Supply (VCoS) is then determined on the basis of energy sales of respective categories. Accordingly, the
VCoS is determined as shown in the table below:

Table 140: Voltage Wise Cost of Supply (VCoS)


Allocated Allocated Total Cost Energy
VCoS
Category Fixed Cost Variable Cost (INR Sales
(INR/kwh)
(INR Crore) (INR Crore) Crore) (MU)
Below 11kV 204.78 145.81 350.59 451.90 7.76
11kV 620.08 678.35 1298.43 2641.96 4.91
66kV 400.76 437.91 838.67 1746.29 4.80
220 kV 376.43 422.59 799.02 1700.62 4.70
Total 1602.04 1684.66 3286.70 6540.77

The VCoS as determined above is used to determine the Cross-Subsidy Surcharge as shown in table below:

Table 141: Cross-Subsidy Surcharge approved by the Commission for FY 2021-22


VCoS ABR Cross- Subsidy
Category
(INR/kWh) (INR/kWh) (INR/kWh)
Below 11kV 7.76 3.95 (3.81)
11kV 4.91 5.30 0.38
66kV 4.80 5.08 0.27
220 kV 4.70 5.15 0.45

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 156
DNH Power Distribution Corporation Limited
Open Access Charges Joint Electricity Regulatory Commission (JERC)

Therefore, the Commission approves INR 0.38/kWh for 11 kV, INR 0.27/kWh for 66 kV, INR
0.45/kWh for 220 kV consumers and Nil for below 11 kV consumers as Cross-Subsidy Surcharge
for FY 2021-22.

Other Charges

All other charges would be as per the JERC (Connectivity and Open Access in Intra-State Transmission and
Distribution) Regulations, 2017 as amended from time to time.

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 157
DNH Power Distribution Corporation Limited
Fuel and Power Purchase Adjustment Mechanism Joint Electricity Regulatory Commission (JERC)

8. Chapter 8: Fuel and Power Purchase


Adjustment Mechanism
The State of Goa and Union Territories of Andaman & Nicobar Islands, Lakshadweep, Chandigarh, Dadra
Nagar Haveli & Daman Diu and Puducherry receive power from the Central Generating Stations, State
Generating Stations, Independent Power Producer’s (IPP’s) through the long-term power purchase agreements
and short term purchases – through exchange, bilateral purchases etc. The distribution licensees of JERC
procure power from various available sources and supply power to the consumers at retail tariffs determined by
the Commission. Power purchase cost accounts for more than 80% of the Annual Revenue Requirements (ARR)
of the distribution licensees and includes the cost paid for procurement of power, transmission charges,
Deviation Settlement Mechanism (DSM) charges, State Load Dispatch Center (SLDC)/ Regional Load Dispatch
Center (RLDC) charges and is netted off with revenue earned from the sale of surplus power.

The cost of the long term power being procured by the distribution licensees is fixed by the Central Electricity
Regulatory Commission (CERC) for plants supplying power to more than one State/UT (for example NTPC,
NHPC etc.) and by the JERC for plants located within its territory/state (for IPP’s, licensees own generation
and other State generating sources). Charges for the Over-drawl/Under-drawl from the Grid and the Inter State
Transmission charges, RLDC charges are fixed by the CERC, while Intra-State Transmission charges and SLDC
charges are fixed by the JERC. Short term purchase/ sale of power is done through traders, bilateral contracts,
banking and power exchanges at market determined prices.

While determining retail tariff for any year, the Commission first determines the ARR based on the projection
of various cost elements including power purchase cost. Power purchase cost of the distribution licensee is
derived from the power purchase quantum and per unit power purchase cost. Quantum of power purchase
depends upon the energy sales to the retail consumer and distribution losses, out of which energy sales is not
under the control of the distribution licensee. There is also variation in actual per unit power purchase cost vis-
a-vis projected per unit power purchase cost due to change in fuel cost, change in power purchase mix i.e.
thermal /hydel/renewable mix, long term/short term power mix etc. This makes power purchase cost
uncontrollable in nature.

The Commission undertakes the truing up exercise for the variation in the cost and revenue once the audited
accounts of the distribution licensee are available. For example, True-up of the FY 20220-21 will be undertaken
by the Commission once the audited accounts of the FY 2020-21 are available. If the audited accounts for the
FY 2020-21 are prepared timely, the impact of True-up of various cost and revenue items is allowed in the tariff
of the FY 2022-23, along with the carrying cost for 2 years. As the power purchase cost is the major cost
element of the ARR of the distribution licensee, adjustment due to change in power purchase cost at regular
intervals is important in order to avoid the burden of carrying cost on the additional power purchase cost
incurred during the year.

Legal Provisions
The relevant provisions of the Electricity Act, Regulations, Policy document and the ATE judgments, which
enable the Commission to devise, adopt and implement a power purchase/ fuel price adjustment mechanism
are as follows: -

(a) Electricity Act, 2003- Section 62 (4)


“No tariff or part of any tariff may ordinarily be amended more frequently than once in any financial
year, except in respect of any changes expressly permitted under the terms of any fuel surcharge
formula as may be specified.”

(b) Tariff Policy, 2016, clause 5.11 – sub clause (h-4)


Fuel and Power Purchase Adjustment Mechanism Joint Electricity Regulatory Commission (JERC)

“Uncontrollable costs should be recovered speedily to ensure that future consumers are not burdened
with past costs. Uncontrollable costs would include (but not limited to) fuel costs, costs on account of
inflation, taxes and cess, variations in power purchase unit costs including on account of adverse
natural events.”
(c) Tariff Policy, 2016, clause 8.2– sub clause 8.2.1-(1)
“8.2 Framework for revenue requirements and costs
Actual level of retail sales should be grossed up by normative level of T&D losses as indicated in MYT
trajectory for allowing power purchase cost subject to justifiable power purchase mix variation (for
example, more energy may be purchased from thermal generation in the event of poor rainfall) and
fuel surcharge adjustment as per regulations of the SERC.”
(d) Hon’ble ATE judgment in OP1 of 2011 dated 11 November, 2011
The Hon’ble ATE directed the SERCs to develop a power purchase cost adjustment mechanism within
six months of the date of the Order. The relevant excerpt of the Order is shown as follows:
“(vi)Fuel and Power Purchase cost is a major expense of the distribution Company which is
uncontrollable. Every State Commission must have in place a mechanism for Fuel and Power Purchase
cost in terms of Section 62 (4) of the Act. The Fuel and Power Purchase cost adjustment should
preferably be on monthly basis on the lines of the Central Commission’s Regulations for the generating
companies but in no case exceeding a quarter. Any State Commission which does not already have
such formula/mechanism in place must within 6 months of the date of this Order must put in place
such formula/mechanism.”

Existing Formula

The Commission first introduced the provision for adjustment of fuel surcharge in the Joint Electricity
Regulatory Commission for the State of Goa and UT’s (Terms and conditions for determination of tariff)
Regulations, 2009 notified on 08 February 2010. The relevant Clause 7 of the Regulations is provided below:

“7. Fuel Surcharge Formula

(1) The fuel cost revisions for the generating companies/units owned by the licensee that are due to reasons
beyond the control of the generating companies / the licensee be in accordance with the fuel surcharge
formula as may be decided by the Commission from time to time.
(2) The generating company or the licensee may determine such charge in accordance with the specified
formula and recover the same from such categories of consumers or the licensees, as the case may be after
following procedure and the terms and conditions attached thereto.”

The Commission subsequently notified the Joint Electricity Regulatory Commission for the State of Goa and
UT’s (Terms and conditions for determination of tariff) (First Amendment) Regulations, 2009 on 27 June, 2012
prescribing the methodology for determination and the recovery mechanism of Fuel & Power Purchase Cost
Adjustment (FPPCA) formula. Subsequently on 18 January, 2013, the Commission issued a Corrigendum
correcting the calculations of the FPPCA for certain consumer categories.

On 30 June, 2014 the Commission notified the Joint Electricity Regulatory Commission for the State of Goa
and Union Territories (Multi Year Distribution Tariff) Regulations, 2014 wherein the Commission proposed to
adopt the same methodology as prescribed in the Joint Electricity Regulatory Commission for the State of Goa
and UT’s (Terms and conditions for determination of tariff) (First Amendment) Regulations, 2009 in the MYT
Period. Clause 19 of the Regulations is shown as follows:

“19. Treatment of Incremental Power procurement cost

The Distribution Licensee shall recover the incremental cost on account of fuel & power purchase adjustment
in accordance with FPPCA formula provided in JERC Terms & Condition for determination of Tariff (first
amendment) Regulations, 2009.”

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 159
DNH Power Distribution Corporation Limited
Fuel and Power Purchase Adjustment Mechanism Joint Electricity Regulatory Commission (JERC)

On 19 October, 2016 JERC notified the Joint Electricity Regulatory Commission for the State of Goa and UT’s
(Multi Year Distribution Tariff) (Second Amendment) Regulations, 2016 according to which the Fuel and Power
Purchase cost adjustment charge shall be levied by distribution licensees on consumer electricity bills on
account of the incremental power purchase cost incurred by the licensees and the Transmission charge recovery
was also added to the formula. The relevant amendment to the Regulation has been shown as follows:

Periodicity for recovery (Cycle)

The licensee shall compute the fuel and power procurement cost variations on a quarterly basis. The adjustment
shall be made in the consumers’ bills starting after a month following the end of the quarter on the units billed
in the months following the quarter.
For example, FPPCA for the quarter April- June shall be done in the month of July and shall be reflected in the
consumer bills raised in the months of August, September and October on the units billed for the months of
July, August and September respectively.

Chargeability

FPPCA charges shall be levied on all consumer categories excluding Below Poverty Line (BPL) and Agriculture
category consumers on per unit basis on monthly/ bi-monthly consumption depending on the billing cycle.

1. Formula

The FPPCA formula shall contain the following three components:

1. Power Purchase Cost adjustments which shall contain the following elements:
• Variation in the Power Purchased from long term/ firm sources viz. CGS, IPP’s, State, Own generation
etc. This may consist of fixed cost, variable costs, arrears, other charges but excluding any kind of
penalties
• Variation in Short term power purchase cost through IEX, Bilateral etc. (shall be allowed upto a certain
ceiling rate as may be fixed in the Tariff Order by the Commission).
• Variation on account of Deviation Settlement Mechanism – Shall be allowed, but the incentive/penalty
shall be excluded

2. Transmission cost adjustments which shall contain the following elements:


• Variation on account of Central Transmission Charges including arrears/ revisions.
• Variation on account of State Transmission charges including arrears/revisions

3. Other Charges which shall contain all the other elements not forming part of the above two components
for example:
• Any adjustments /reversals due to over recovery of charges
• Any adjustments due to under recovery of charges in case the Commission decides to limit the FPPCA
charges in previous quarters to avoid tariff shock or other reasons
• Any other adjustments on account of factors not envisaged at the time of tariff fixation

4. Less any revenue from Additional Surcharge collected from Open Access consumer towards the
stranded power purchase cost.

Based on the components as defined above, the new FPPCA formula can be represented as follows:

𝑹𝒔. (𝑷𝒂𝒄𝒕 + 𝑻𝒂𝒄𝒕 + 𝑶𝒂𝒄𝒕 − 𝑨𝑺𝒂𝒄𝒕) ∗ 𝟏𝟎


𝑭𝑷𝑷𝑪𝑨 ( ) =. ( ) − 𝑹𝒂𝒑𝒑
𝑼𝒏𝒊𝒕 {[𝑷𝑷𝑶𝒂𝒄𝒕 ∗ (𝟏 − 𝑻𝑳𝒂𝒑𝒑) + 𝑷𝑷𝑰𝒂𝒄𝒕 − 𝑷𝑺𝑶𝒂𝒄𝒕] ∗ (𝟏 − 𝑫𝑳𝒂𝒑𝒑)} − 𝒁𝒂𝒄𝒕
Where:
• 𝑃𝑎𝑐𝑡(𝑖𝑛 𝑅𝑠. 𝐶𝑟. ): Actual Power purchase cost inclusive of fixed cost, variable costs, arrears, and other
charges excluding any kind of penalties incurred in the quarter. This shall include:
o Cost of procurement from sources outside the State,
o Cost of procurement from sources within the State,
o Cost of DSM excluding any penal charges,
o Cost of procurement from the Bilateral/ exchange etc.
o Less: Revenue from sale of surplus power/ DSM
• 𝑇𝑎𝑐𝑡 (𝑖𝑛 𝑅𝑠. 𝐶𝑟. ): Actual Transmission cost inclusive of any kind of arrears, other charges etc. and
excluding any kind of penalties incurred in the quarter. This shall include:
o Inter-State transmission cost (PGCIL charges),

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 160
DNH Power Distribution Corporation Limited
Fuel and Power Purchase Adjustment Mechanism Joint Electricity Regulatory Commission (JERC)

o Intra-State transmission cost


• 𝑂𝑎𝑐𝑡 (𝑖𝑛 𝑅𝑠. 𝐶𝑟. ): Adjustments from the previous FPPCA quarter on account of over/ under recovery
and any other incidental costs not accounted for at the time of retail tariff fixation
• 𝐴𝑆𝑎𝑐𝑡 (𝑖𝑛 𝑅𝑠. 𝐶𝑟. ): Revenue from Additional Surcharge collected from Open Access consumer towards
the stranded power purchase cost
• 𝑃𝑃𝑂𝑎𝑐𝑡 (𝑖𝑛 𝑀𝑈): Quantum of power purchased in the quarter from sources outside State/ Union
Territory
• 𝑇𝐿𝑎𝑝𝑝 (𝑖𝑛 %): Approved Inter- State transmission losses for the year in consideration as provided in the
relevant Tariff Order
• 𝑃𝑃𝐼𝑎𝑐𝑡 (𝑖𝑛 𝑀𝑈): Quantum of power purchased in the quarter from sources within State/Union
Territory, Bilateral/ Exchange and Over-drawal under the DSM
• 𝑃𝑆𝑂𝑎𝑐𝑡 (𝑖𝑛 𝑀𝑈): Actual quantum of sale of surplus power/ under-drawal under the DSM in the quarter
• 𝐷𝐿𝑎𝑝𝑝 (𝑖𝑛 %): Approved T&D losses for the year in consideration as provided in the relevant Tariff
Order
• 𝑍𝑎𝑐𝑡 (𝑖𝑛 𝑀𝑈): Actual energy sales for agriculture and LIG category consumers in the quarter

𝑅𝑠 (𝑃𝑎𝑝𝑝 + 𝑇𝑎𝑝𝑝 ) ∗ 10
𝑅𝑎𝑝𝑝 ( )=( )
𝑢𝑛𝑖𝑡 {[𝑃𝑃𝑂𝑎𝑝𝑝 ∗ (1 − 𝑇𝐿𝑎𝑝𝑝) + 𝑃𝑃𝐼𝑎𝑝𝑝 − 𝑃𝑆𝑂𝑎𝑝𝑝] ∗ (1 − 𝐷𝐿𝑎𝑝𝑝)} − 𝑍𝑎𝑝𝑝
• 𝑃𝑎𝑝𝑝 (𝑖𝑛 𝑅𝑠. 𝐶𝑟. ): Total power purchase cost approved in the Tariff Order for a quarter inclusive of
fixed costs, variable costs etc. and containing the following elements:
o Cost of procurement from sources outside the State,
o Cost of procurement from sources within the State,
o Cost of procurement from the Bilateral/ exchange etc.
o Less: Revenue from sale of surplus power
• 𝑇𝑎𝑝𝑝 (𝑖𝑛 𝑅𝑠. 𝐶𝑟. ): Total transmission charges approved in the Tariff Order for a quarter consisting of
the following elements:
o Inter-State transmission charges (PGCIL charges),
o Intra-State transmission charges
• 𝑃𝑃𝑂𝑎𝑝𝑝 (𝑖𝑛 𝑀𝑈): Quantum of power to be procured from sources outside State/ Union Territory in a
quarter as approved in the Tariff Order
• 𝑇𝐿𝑎𝑝𝑝 (𝑖𝑛 %): Approved Inter- State transmission losses for the year in consideration as provided in
the relevant Tariff Order
• 𝑃𝑃𝐼𝑎𝑝𝑝 (𝑖𝑛 𝑀𝑈): Quantum of power to be procured from sources within the State, bilateral/ exchange
in a quarter as approved in the Tariff Order
• 𝐷𝐿𝑎𝑝𝑝 (𝑖𝑛 %): Approved T&D losses for the year in consideration as provided in the Tariff Order
• 𝑃𝑆𝑂𝑎𝑝𝑝 (𝑖𝑛 𝑀𝑈): Quantum of sale of surplus power approved in the Tariff Order for a quarter
• 𝑍𝑎𝑝𝑝 (𝑖𝑛 𝑀𝑈): Sales for agriculture and LIG category consumers for a quarter as approved in the
relevant Tariff Order

2. Other Terms and conditions

1. For the purpose of the Fuel and Power Purchase Cost Adjustment, all the bills admitted and credits, if
any, received by the distribution licensee during the period in consideration, irrespective of the period
to which they pertain, may be considered.

2. The FPPCA charges determined as per the formula above may be recovered from the consumers of all
categories based on their billed units excluding the LIG and the agriculture category consumers.

3. The FPPCA charges for a quarter shall be limited to a +10% of the ABR of the consumer category. The
distribution licensee shall be allowed to collect the FPPCA without obtaining approval from the
Commission. However, the distribution licensee shall be required to submit the FPPCA calculation to
the Commission at least one week before levying the same on the consumers. In case FPPCA is more
than +10% of ABR, the licensee shall charge full/higher FPPCA only with prior approval from the
Commission.

4. The per unit FPPCA so worked out is charged differentially as per the approved retail tariff of the
consumers. The determination of differential per unit FPPCA is mentioned below:

• Step 1: Determination of Value of K

Order on True-up of FY 2019-20, APR for FY 2020-21 and ARR for FY 2021-22 161
DNH Power Distribution Corporation Limited
Fuel and Power Purchase Adjustment Mechanism Joint Electricity Regulatory Commission (JERC)

𝑅𝑠.
𝐴𝑝𝑝𝑟𝑜𝑣𝑒𝑑 𝑅𝑒𝑡𝑎𝑖𝑙 𝑇𝑎𝑟𝑖𝑓𝑓 𝑓𝑜𝑟 𝑎 𝑐𝑎𝑡𝑒𝑔𝑜𝑟𝑦 𝑜𝑟 𝑠𝑢𝑏 𝑐𝑎𝑡𝑒𝑔𝑜𝑟𝑦 ( )
𝑢𝑛𝑖𝑡
𝑅𝑠.
𝑊𝑒𝑖𝑔ℎ𝑡𝑒𝑑 𝐴𝑣𝑒𝑟𝑎𝑔𝑒 𝑅𝑒𝑡𝑎𝑖𝑙 𝑇𝑎𝑟𝑖𝑓𝑓 (𝑊𝐴𝑅𝑇)( )
𝑢𝑛𝑖𝑡
The value of K for different consumer category or subcategory for the year in consideration is considered as
approved in this Tariff Order.
• Step 2: Determination of proportionate FPPCA (INR/unit) consumer category/sub-category
wise
𝑅𝑠.
𝐹𝑃𝑃𝐶𝐴 ( ) = 𝐴𝑣𝑒𝑟𝑎𝑔𝑒 𝐹𝑃𝑃𝐶𝐴 ∗ 𝐾 𝑓𝑜𝑟 𝑡ℎ𝑎𝑡 𝑐𝑜𝑛𝑠𝑢𝑚𝑒𝑟 𝑐𝑎𝑡𝑒𝑔𝑜𝑟𝑦 𝑜𝑟 𝑠𝑢𝑏 − 𝑐𝑎𝑡𝑒𝑔𝑜𝑟𝑦
𝑈𝑛𝑖𝑡
5. The Petitioner shall compute fuel and power procurement cost variations, and adjustments shall be
made in the consumer bills based on the Fuel and Power Purchase Cost Adjustment (FPPCA) formula
notified by the Commission in this Order.

For the purpose of calculation, the approved per unit cost of power purchase (Rapproved) shall be taken as INR per
unit for the FY 2021-22 as shown in following table.

Table 142: Rapproved determined by Commission for FY 2021-22


S.
Particulars Value
No.
1 Total Power Purchase Cost (INR Crore), Papp 2711.97
2 Transmission Charges (INR Crore), Tapp 522.17
3 Power Purchase Quantum from CGS Stations at Generator Ex-bus (NTPC,
6847.42
NSPCL, NPCIL, EMCO) (MU), PPOapp
4 Approved Weighted Average Inter-State Transmission Loss (%), TLapp 3.66%
5 Power Purchase Quantum from sources within State/ Open Market, PPIapp 175.20
6 Quantum of Sale of Surplus Power (MU), PSOapp -
7 Approved Intra-State T&D Loss (%), DLapp 4.10%
8 Energy Sales for LIG and Agriculture consumer category (MU), Zapp (MU) 5.46
9 Rapp (INR/kWh) 4.98

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DNH Power Distribution Corporation Limited
Directives Joint Electricity Regulatory Commission (JERC)

9. Chapter 9: Directives
Over the years, the Commission has issued various directives to the Petitioner for necessary action at its end. It
has been observed that the Petitioner is not fully complying with many of the directives issued by the
Commission. In order to strengthen the effective monitoring and ensure timely implementation of all the
directives in true spirit, the Commission hereby directs that the Petitioner shall now compulsorily submit:

• The detailed action plan for compliance of all the directives within 1 month of the
issuance of this Order.
• The quarterly progress report as per the detailed action plan for all the directives issued in the
subsequent sections within 15 days of the end of each quarter of the calendar year.

Directives Continued/ Dropped in this Order


While examining the compliance note and supporting documents submitted by the Petitioner in the present
Petition, it is observed that some of the directives issued in the previous Tariff Orders have not been fully
complied with by the Petitioner.
The Commission is of the view that substantial time has already been given to the utility for compliance with
these directions. Thus, the Commission hereby directs the utility to comply with the directions mentioned
below in the given timeframe, failing which the Commission shall be constrained to initiate necessary action
under Section 142 of the Electricity Act 2003 read with other provisions of the Act, and the Regulations made
thereunder.

9.1.1. Quarterly Statement of Capital Expenditure

Originally Issued in Tariff Order dated 31st July 2012


Commission’s Directive in Tariff Order Dated 20th May 2019
With regards to non-submission of quarterly report on capital expenditure and capitalization, the Commission
directed the Petitioner as follows:
The Commission has noted with concern that Petitioner is yet to submit the details as sought by the
Commission. The Commission now directs the Petitioner to ensure compliance of this directive and submit the
desired reports on quarterly basis, failing which the Commission will be constrained to take appropriate action
against the Petitioner.

Petitioner’s Response
The DNHPDCL would like to submit that the Quarterly report will be submitted to the Commission shortly.

Commission’s Response
The Commission has noted with concern that Petitioner is yet to submit the details as sought by the
Commission. The Commission now directs the Petitioner to ensure compliance of this directive within three
months from the date 0f issuance of this order and submit the desired reports regularly on quarterly basis,
failing which the Commission will be constrained to take appropriate action against the Petitioner.
Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit that the Quarterly report will be submitted to the Commission shortly.

Commission’s direction in this Tariff Order


The Commission has noted with concern that Petitioner is yet to submit the details as sought by the
Commission. The Commission now directs the Petitioner to ensure compliance of this directive within three
months from the date 0f issuance of this order and submit the desired reports regularly on quarterly basis,
failing which the Commission will be constrained to take appropriate action against the Petitioner.

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DNH Power Distribution Corporation Limited
Directives Joint Electricity Regulatory Commission (JERC)

9.1.2. Implementation of Smart Grid


Originally Issued in Tariff Order dated 07th April 2016
Commission’s Directive in Tariff Order Dated 20th May 2019
The Commission notes the submission of the Petitioner with concern and directs it to submit a detailed action
plan by 30th September 2019 for roll out of smart grid in DNH within this MYT Control Period.

Petitioner’s Response
The DNHPDCL would like to submit that the possibility of implementation of Smart Grid in UT of DNH will be
explored in due course.

Commission’s Response
The Commission notes the submission of the Petitioner with concern and directs it to submit a detailed action
plan by 30th September 2020 for rolling out of the smart grid in DNH within this MYT Control Period.
Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit the Silvassa town is declared as a Smart City. Accordingly, measures will
be taken up for implementation of Smart Grid projects.
Commission’s direction in this Tariff Order
The Commission notes the submission of the Petitioner with concern and directs it to submit a detailed action
plan by 30th September 2021 for rolling out of the smart grid in DNH district within this MYT Control Period.

9.1.3. Information for determination of Voltage-wise Wheeling


Charges

Originally Issued in Tariff Order dated 07th April 2016


Commission’s Directive in Tariff Order Dated 20th May 2019
The Commission notes the compliance by the Petitioner. However, the Petitioner has shown no allocation at
EHT level though a few consumers are being supplied at 220 kV. The Commission directs the Petitioner to carry
out allocation in scientific manner and submit revised allocation along with Tariff Petition for FY 20-21.
Petitioner’s Response
The DNHPDCL would like to submit that the details for the EHT consumers shall be submitted to the
Commission shortly.

Commission’s Response
The Commission notes the submission of the Petitioner with concern and directs it to submit details of voltage
wise assets and expenses along with the allocation methodology including allocation at EHT level along with
next Tariff Petition.
Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit that the details for the EHT consumers shall be submitted to the
Commission shortly.

Commission’s direction in this Tariff Order


The Commission notes the submission of the Petitioner with concern and directs it to submit details of voltage
wise assets and expenses along with the allocation methodology including allocation at EHT level along with
next Tariff Petition

9.1.4. Timely Submission of Reports


Originally Issued in Tariff Order dated 18th May 2020
Commission’s Directive in Tariff Order Dated 18th May 2020
The Commission has observed that the Petitioner do not submit the quarterly or any other report within time as
specified by the Commission in previous Orders. Accordingly, the Petitioner is directed to comply with the

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Directives Joint Electricity Regulatory Commission (JERC)

timelines decided by the Commission for all such reports.


Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit that the reports pertaining to RPO, metering, FPPCA, SAIFI, SAIDI are
submitted to the Commission on a regular basis.
Commission’s direction in this Tariff Order
The Commission has noted the compliance to the above directive and noticed that the petitioner has not
submitted the report related to SAIFI/SAIDI in past on regular basis. Accordingly, the Commission directs the
petitioner to submit the aforementioned reports regularly in future.

9.1.5. Quarterly RPO Compliance Report Submission


Originally Issued in Tariff Order dated 18th May 2020
Commission’s Directive in Tariff Order Dated 18th May 2020
The Commission directs the Petitioner to submit quarterly RPO report henceforth timely within 15 days of the
subsequent quarter.
Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit that RPO reports are being submitted quarterly to the Commission.
Commission’s direction in this Tariff Order
The Commission has noted the compliance to the above directive and directs the petitioner to submit the
aforementioned quarterly report regularly in future also. Accordingly, the Commission now drops this
directive.

9.1.6. Quarterly details of Stranded Power (Open Access)


Originally Issued in Tariff Order dated 18th May 2020
Commission’s Directive in Tariff Order Dated 18th May 2020
The Commission directs the Petitioner to submit quarterly details of power stranded on account of consumers
opting for open access along with the Additional Surcharge recovered from these consumers.
Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit that at present there is no open access consumer and therefore there is no
stranded power.
Commission’s direction in this Tariff Order
The Commission has noted the compliance to the above directive and directs the petitioner to submit the
aforementioned report in future if the power is availed by the consumers through open access.

9.1.7. Status of Metering


Originally Issued in Tariff Order dated 18th May 2020
Commission’s Directive in Tariff Order Dated 18th May 2020
The Commission directs the petitioner to submit the metering status including status of defective meters for
each category of consumers separately within three months from the issuance of this Tariff Order. Further, the
petitioner is also directed to submit the status of the consumers for which billing is being done on metered basis
and assessment basis within three months from the issuance of this Tariff Order.
Petitioner’s Response in the Present Tariff Petition
The DNHPDCL would like to submit that the details regarding metering have submitted to the Commission as
per the format provided to the utilities. Further, all the details were also submitted during the course of Suo-
moto hearing to the Commission.
Commission’s direction in this Tariff Order
The Commission has noted the compliance to the above directive and directs the petitioner to submit the
aforementioned report regularly in future also. Accordingly, the Commission now drops this directive.

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DNH Power Distribution Corporation Limited
Tariff Schedule Joint Electricity Regulatory Commission (JERC)

10. Chapter 10: Tariff Schedule

Tariff Schedule
Table 143: Tariff Schedule for FY 2021-22
S. No. Category Fixed Charges Energy Charges
1. DOMESTIC
(i) 0-50 units 1.40 INR/kWh
(ii) 51-200 units 2.10 INR/kWh
10.00 INR/Con/Month
(iii) 201-400 units 2.60 INR/kWh
(iv) 401 and above 3.20 INR/kWh
Power supply to low income group
connections will be charged at INR 20 per
service connection per month. For any
Low Income Group
(v) unauthorized increase in the load beyond
(Up to 2x40 W bulbs only)
2*40 watts, penal charges at the rate of INR
20 per month per point will be levied and the
installation will be liable for disconnection.

2. NON DOMESTIC/COMMERCIAL
(i) 0-100 units 20.00 INR/Con/Month 3.10 INR/kWh
(ii) 101 units and above 20.00 INR/Con/Month 4.10 INR/kWh

3. LT INDUSTRIAL
(a) LTP Motive Power
(i) Up to 20 HP 20.00 INR/HP/Month 3.50 INR/kVAh
(ii) Above 20 HP 80.00 INR/HP/Month 3.70 INR/kVAh
(b) LT Public Water Works
(i) Up to 20 HP 50.00 INR/HP/Month 4.60 INR/kWh
(ii) Above 20 HP 100.00 INR/HP/Month 4.60 INR/kWh

4. HT/EHT INDUSTRIAL
(i) 11 kV supply 400.00 INR/kVA/month 4.10 INR/kVAh
(ii) 66 kV supply 525.00 INR/kVA/month 4.05 INR/kVAh
(iii) 220 kV supply 575.00 INR/kVA/month 4.00 INR/kVAh

5. AGRICULTURE AND POULTRY


For sanctioned load up to 10
(i) - 0.75 INR/kWh
HP
(ii) Beyond 10 HP - 1.10 INR/kWh

6. PUBLIC LIGHTING
(i) For all units - 4.05 INR/kWh

HOARDINGS/
7.
SIGNBOARDS
(i) Hoarding/ Signboards INR 100 per kVA per Month or part thereof 7.30 INR/kWh

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Tariff Schedule Joint Electricity Regulatory Commission (JERC)

S. No. Category Fixed Charges Energy Charges

ELECTRIC VEHICLE
8.
CHARGING
(i) Electric Charging Vehicle - 4.70 INR/kWh

9. Temporary Supply
Tariff for Temporary Connection shall be Fixed/ Demand charges (if any) plus energy charges (for
(i) relevant slab, if any) under corresponding permanent supply category plus 50% of both.
For multi activity pursuit, applicable tariff for temporary connection shall be with reference to that
of non-domestic category for permanent supply.

Applicability
Table 144: Applicability of Tariff Schedule for FY 2021-22
S. No Category Applicability
This schedule shall apply to private houses, hospitals run on
Non-commercial lines, Government Schools (including
1. Domestic Government Schools Hostels), Charitable Religious Institutions
for Light, Fans, Radios, Domestic Heating and other household
appliances including water pumps up to 2 HP.

This schedule shall apply to Shops, Offices, Restaurants, Bus


Stations, Schools (other than Govt. schools & their hostels),
Photo Studios, Laundries, Cinema Theatres, Industrial Lighting,
Non Domestic/ clubs and other Commercial installations.
2.
Commercial
This includes all categories which are not covered by other tariff
categories including Domestic Category, Low Income Group,
Industrial LT, HT/EHT Category (A&B), Agriculture and
Poultry, Public Lighting.

This schedule shall apply to all Low Tension Industrial Motive


3. LT Industrial Power Connections including water works/pumps with
sanctioned load up to 99 HP.

This schedule shall apply to all Industrial/Motive power/ Ferro


4. HT 11 kV supply Metallurgical / Steel Melting / Steel Rerolling / Power Intensive
consumers drawing through 11 kV systems

This schedule shall apply to all Industrial/Motive power/ Ferro


5. HT 66 kV supply Metallurgical / Steel Melting / Steel Rerolling / Power Intensive
consumers drawing through 66 kV systems

This schedule shall apply to all Industrial/Motive power/ Ferro


6. HT 220 kV supply Metallurgical / Steel Melting / Steel Rerolling / Power Intensive
consumers drawing through 220 kV systems

Agriculture and This schedule shall apply to Agriculture or poultry loads up to


7.
Poultry 99 HP sanctioned load will be considered in this category.

8. Public Lighting -
Hoardings / This schedule shall apply to electricity for lighting external
9.
Signboards advertisements, external hoardings and displays at departments

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DNH Power Distribution Corporation Limited
Tariff Schedule Joint Electricity Regulatory Commission (JERC)

S. No Category Applicability
stores, malls, multiplexes, theatres, clubs, hotels, bus shelters,
Railway Stations shall be separately metered and charged at the
tariff applicable for "Advertisements and Hoardings" category,
except such displays which are for the purpose of indicating /
displaying the name and other details of the shop, commercial
premises itself. Such use of electricity shall be covered under the
prevailing tariff for such shops or commercial premises. The
connection for "Advertisements and Hoardings" category would
be covered under the permanent supply of connection.

The Temporary Tariff is applicable for a temporary period of


10. Temporary Supply supply for a period of maximum one (1) year at a time, which
may be further extended, as per the provisions of Supply Code
Regulations.

This tariff schedule shall apply to consumers that have set up


Public Charging Stations (PCS) in accordance with the technical
Electric Charging norms/ standards/specifications laid down by the Ministry of
11. Power, GoI and Central Electricity Authority (CEA) from time to
Station
time.
The tariff for domestic consumption shall be applicable for
domestic charging (LT/HT).

General Conditions of HT and LT Supply


1. The tariffs are exclusive of electricity duty, taxes and other charges levied by the Government or other
competent authority from time to time which are payable by the consumers in addition to the charges levied
as per the tariffs.

2. Unless otherwise agreed to, these tariffs for power supply are applicable for supply at one point only.

3. Supply to consumers having contracted load between 100 KVA to 5000 KVA (including licensee common
feeders and express feeders/dedicated feeders) shall generally be at 11 KV and for more than 5000 KVA up
to 25000 KVA at 66 KV. For the consumer who requires load more than 25000 KVA, the supply voltage
shall be at 220 KV level.

4. If energy supplied for a specific purpose under a particular tariff is used for a different purpose not
contemplated in the contract for supply and/or for which a higher tariff is applicable, it will be deemed as
unauthorized use of electricity and shall be dealt with for assessment under the provisions of Section 126 of
the Electricity Act, 2003 & Supply Code Regulation notified by JERC.

5. If connected load of a domestic category is found to be at variance with the sanctioned/contracted load as a
result of replacement of appliances such as lamps, fans, fuses, switches, low voltage domestic appliances,
fittings, it shall not fall under Section 126 and Section 135 of the EA 2003.

6. Power Factor Charges - LT Commercial and Agriculture Connection running without proper
capacitors installed so as to maintain Power Factor of 0.85 as per the JERC Supply Code Regulations,
2018 and subsequent amendment thereof shall be charged extra 2.5% of units consumed as additional
power factor charges. Payment of the power factor charge won't exempt the consumer from his
responsibility to maintain the power factor. The conditions for disconnection of a consumer supply in
case of non-achievement of minimum level of power factor as prescribed in the Supply Code
Regulations notified by JERC, shall apply. DNHPDCL may install a suitable capacitor at its own cost

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Tariff Schedule Joint Electricity Regulatory Commission (JERC)

and recover the cost thereof as arrears of energy charges. In case the monthly average power factor is
less than 0.70 lagging, the installation is liable for disconnection after due notice.

7. If the consumer fails to pay the energy bill presented to him by the due date, the Department shall have the
right to disconnect the supply after giving 15 days' notice as per the provisions of the Act and the Supply
Code Regulations.

8. Fixed charges, wherever applicable, will be charged on pro-rata basis from the date of release of connection.
Fixed charges, wherever applicable, will be double as and when bi-monthly billing is carried out. Similarly,
slabs of energy consumption will also be considered accordingly in case of bi-monthly billing.

9. The billing in case of HT/EHT shall be on the maximum demand recorded during the month or 85% of
contracted demand, whichever is higher. If in any month, the recorded maximum demand of the consumer
exceeds its contracted demand, that portion of the demand in excess of the contracted demand shall be
billed at double the normal rate. Similarly, energy consumption corresponding to excess demand shall also
be billed at double the normal rate. The definition of the maximum demand would be in accordance with
the provisions of the JERC Supply Code Regulations. If such over-drawal is more than 20% of the contract
demand, then the connections shall be disconnected immediately.

Explanation: Assuming the contract demand as 100 KVA, maximum demand at 120 KVA and total energy
consumption as 12000 kWh, then the consumption corresponding to the contract demand will be 10000
kWh (12000*100/120) and consumption corresponding to the excess demand will be 2000 kWh. This
excess demand of 20 KVA and excess consumption of 2000 kWh will be billed at twice the respective
normal rate. Such connections drawing more than 120 kVA, shall be disconnected immediately.

10. Unless specifically stated to the contrary, the figures of energy charges relate to paisa per unit (kWh) charge
for the energy consumed during the month.

11. Delayed payment surcharge shall be applicable to all categories of consumers. Delayed payment surcharge
of 2% per month or part thereof shall be levied on all arrears of bills. Such surcharge shall be rounded off to
the nearest multiple of one rupee. Amount less than 50 paisa shall be ignored and amount of 50 paisa or
more shall be rounded off to the next rupee. In case of permanent disconnection, delayed payment
surcharge shall be charged only up to the month of permanent disconnection.

12. Advance Payment Rebate: If payment is made in advance well before commencement of the
consumption period for which the bill is prepared, a rebate @ 1% per month shall be given on the amount
(excluding security deposit) which remains with the licensee at the end of the month. Such rebate, after
adjusting any amount payable to the licensee, shall be credited to the account of the consumer.

13. Prompt Payment Rebate: If payment is made at least 7 days in advance of the due date of payment, a
rebate for prompt payment @ 0.25 % of the bill amount shall be given. Those consumers having arrears
shall not be entitled for such rebate.

14. The adjustment on account of Fuel and Power Purchase Cost variation shall be calculated in accordance
with the FPPCA formula notified in Chapter 8 of this Order. Such charges shall be recovered/refunded in
accordance with the terms and conditions specified in the FPPCA formula.

15. The values of the 'K' factor applicable for the different consumer categories for use in the FPPCA formula
shall be as specified in this Tariff Order for the FY 2020-21.

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Tariff Schedule Joint Electricity Regulatory Commission (JERC)

Schedule of Miscellaneous Charges


Table 145: Schedule of Miscellaneous Charges for FY 2020-21
Description Approved Charges

Monthly Meter Rental Charges

Single Phase LT meter INR 10 per month or part thereof

Three Phase LT meter INR 25 per month or part thereof

LT Meter with MD indicator INR 200 per month or part thereof

Tri-vector Meter INR 500 per month or part thereof


Note:
The type of meters to be installed in consumer premises will be decided by the department. Generally the
consumers having connected load above 50 HP will be provided with L.T.M.D meters
Reconnection Charges

LT Services
• Single Phase LT INR 50/-
• Three Phase LT INR 100/-

HT Services INR 1000/-


Note: If the same consumer seeks reconnection within 12 months from the date of reconnection or
disconnection, 50% will be added to above charges
Testing Fee for Various Metering Equipments

Single Phase INR 100/-

Three Phase INR 300/-

Three Phase Tri-vector Meter (0.5 Class) Industrial LT Consumer INR 500/-

Three Phase Tri-vector Meter (0.5 Class) 11 kV HT Consumer INR 500/-

Three Phase Tri-vector Meter (0.2 Class) 66 KV EHT Consumers INR 1000/-

Combined CT/PT Unit for 11 KV Consumer INR 500/-

66 KV CT/ PT Unit INR 500/-

Three Phase CT Block INR 300/-

CT Coil INR 100/-

Service Connection Charges

Single Phase LT INR250/-

Three Phase LT INR1,000/-

HT (First 500 KVA) INR10,000/-


INR1,000/- per 100 KVA or part
HT (Beyond 500 KVA)
thereof
Extra Length - Single Phase INR25/- per meter

Extra Length - Three Phase INR50/- per meter


Extra length chargeable will be beyond the permissible 30 meters’ free length from existing network for new
connections for all categories except agriculture. Free length in respect of new agriculture consumer is 300
meters.

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DNH Power Distribution Corporation Limited
Tariff Schedule Joint Electricity Regulatory Commission (JERC)

Description Approved Charges


Entire Cost of setting up HT connection would be borne by the consumer and 15% supervision charges shall be
recovered by DNHPDCL on labor component only as per JERC Supply Code 2018.
Fees (Non-refundable) for submission of Test Report of wiring Completion

Single Phase Lighting / Domestic INR 10/- Per Test Report

Three Phase Lighting / Domestic INR 25/- Per Test Report

Single Phase Lighting / Non Domestic INR 50/- Per Test Report

Three Phase Lighting / Non Domestic INR 100/- Per Test Report

Three Phase LT Industries INR 250/- Per Test Report


Single Phase / Three phase Agriculture /
INR 50/- Per Test Report
Streetlight / Public Lighting & others
HT Industries upto 500 KVA INR 1,000/- Per Test Report

HT Industries upto 2500 KVA INR 5,000/- Per Test Report

HT Industries above 2500 KVA INR 10,000/- Per Test Report

Registration for Change of Name

1 Phase Domestic / commercial

3 Phase Domestic / commercial 200

LT Industries 500

HT Industries 1000

EHV Industries 2000

Shifting of meter

1 Phase Domestic / commercial 100

3 Phase Domestic / commercial 200

LT Industries 500

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DNH Power Distribution Corporation Limited
Annexures Joint Electricity Regulatory Commission (JERC)

Annexures

Annexure I: List of Stakeholders


The following is the list of the participants who have attended the Virtual Public Hearing on
January 29, 2021:

Table 146: List of participants in Public Hearing


S.
Name of Stakeholder Designation
No.
1 Mr. Chandrakant M. Parekh President FIA, Silvassa

2 Mr. Ravi N. Pandey Vice-President SIMA, Silvassa

3 Dr. R. Shelke Secretary, DNH Industries Association

4 Mr. P. K. Jadia Executive Secretary, FIA, Silvassa

5 Adv. R. N. Purohit Advocate (Consultant)

6 Mr. K. J. Mody Executive President

7 Mr. H. B. Panchal Member Representative

8 Mr. Atul R Shah Rachna Plasticizers

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DNH Power Distribution Corporation Limited

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