RAJASTHAN ELECTRICITY REGULATORY COMMISSION, JAIPUR Petition...

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RAJASTHAN ELECTRICITY REGULATORY COMMISSION, JAIPUR

Petition No. RERC 552/15, 553/15, 554/15

In the matter of determination of Annual Revenue Requirement (ARR) & Retail Supply Tariff of Discoms for FY 2015-16 and approval of true-up of ARR for FY 2013-14 & Investment Plan for FY 2015-16.

Coram: Shri Vishvanath Hiremath, Chairman Shri Vinod Pandya, Member Shri Raghuvendra Singh, Member Petitioners: Jaipur Vidyut Vitran Nigam Ltd. Jaipur (552/15) Ajmer Vidyut Vitran Nigam Ltd. Ajmer (553/15) Jodhpur Vidyut Vitran Nigam Ltd. Jodhpur (554/15) Date of hearing: 25.04.2016, 26.04.2016 and 27.04.2016

Date of Order: 22.09.2016

ORDER

Section-1: Filings, preliminary issues

1.1. The three distribution companies namely, Jaipur Vidyut Vitran Nigam Ltd. (JVVNL), Ajmer Vidyut Vitran Nigam Ltd. (AVVNL) and Jodhpur Vidyut Vitran Nigam Ltd. (JdVVNL), collectively called Discoms or Petitioners had filed petitions on 15.07.2015 for determination of ARR for 2015-16 u/s 62 and 64 of the Electricity Act, 2003 read with Regulation 11 of RERC (Terms & Conditions of Determination of Tariff) Regulations, 2014 (hereinafter referred to as ‘Tariff Regulations, 2014’) along with true-up of ARR for FY 2013-14 without giving the proposals for revision of tariff and for approval of Investment Plan for 2015-16.

1.2. After examining the petitions, the Commission vide letter dated 10.08.2015

pointed out the deficiencies observed.

1.3. On 28.08.2015, Discoms filed amended petitions removing the deficiencies

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pointed out vide letter dated 10.08.2015 of the Commission along with the tariff proposals as per Regulation 11 of RERC (Terms and Conditions for Determination of Tariff) Regulations, 2014.

1.4. After scrutiny of the amended petitions, the Commission again noticed more

deficiencies. These deficiencies were brought to the notice of the Discoms during the meeting held on 22.09.2015 and also through letter dated 22.09.2015.

1.5. JVVNL, AVVNL & JdVVNL, vide their letters dated 09.10.2015, 28.10.2015 & 28.10.2015 respectively, submitted reply to the deficiencies indicated by the Commission vide its letter dated 22.09.2015.

1.6. On receipt of reply of the Discoms along with the additional information, it

was observed that in compliance of Regulations 11(4) & 11(5) of the RERC (Terms and Conditions for Determination of Tariff) Regulations, 2014, which provide for giving information required for processing of tariff petitions ,the Discoms have furnished the following details :-

a) Audited Accounts for FY 2013-14 and Un-Audited Accounts for FY 2014-

15; [Regulation11(4)]

b) A statement of the current Tariff and all applicable terms and conditions and expected revenue from the current tariff for the ensuing year or the period for which the tariff is to be determined; [Regulation 11(5)(a)]

c) Details of subsidy received from the State Government, the consumers

to whom it is directed and showing how the subsidy is reflected in the proposed tariff applicable to those Consumers; [Regulation 11(5) (b)].

d) A statement of the estimated change in annual revenues that would

result from the proposed tariff changes in the period in which they are to be implemented; [Regulation 11(5) (c)].

e) Audited annual statements for the previous year (2013-14), unaudited

statement for the current year (2014-15) and projections for the ensuing year (2015-16); [Regulation 11(5) (d)].

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f) Detailed calculations of voltage-wise cost of supply, (by working out the same as per Hon’ble Tribunal order in Appeal No.102 of 2010) [Regulation 11(5) (f)].

g) Statement showing calculations of the amount of cross subsidy in the

existing Tariff and in the proposed Tariff. [Regulation 11(5) (g)].

1.7. JVVNL, AVVNL and JdVVNL vide their letters dated 04.12.2015, 26.11.2015 and 16.11.2015 respectively filed the updated status of compliance of Commission’s directives. JVVNL also furnished revised submissions on voltage wise cost of supply on 02.12.2015.

1.8. Considering the compliance of Tariff Regulations, and data furnished, the Commission deemed it appropriate to take up the petitions for further consideration. The Commission also asked the Discoms to furnish compiled set of the petitions along with the replies of data gap and additional information furnished to the Commission. The Discoms submitted the compiled set of petitions on 04.12.2015.

1.9. As per Section 64(2) of the Act, 2003 which requires that applicant should

publish application filed in such abridged form and manner as may be specified by the Appropriate Commission, the Commission on 04.12.2015 allowed Discoms to publish the notice in the newspapers. Discoms were also asked to arrange audio-visual presentation for Stakeholders to explain the submissions made in their petitions to the Consumers/Public.

1.10. Accordingly, public notices with salient features of the petitions, inviting

objections/comments/suggestions, were published in the following newspapers on the dates shown against each of the petitions and were also placed on the websites of the Commission and Discoms. The last date for submission of objections/ suggestions was notified as 11.01.2016:

Sr. No. Name of News Paper JVVNL AVVNL JdVVNL

(i) Rajasthan Patrika 09.12.2015 09.12.2015 09.12.2015 (ii) Dainik Bhaskar 09.12.2015 09.12.2015 09.12.2015 (iii) Times of India 10.12.2015 10.12.2015 10.12.2015 (iv) Danik Nav Jyoti 09.12.2015 09.12.2015 - (v) Rashtradoot 09.12.2015 09.12.2015 -

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Sr. No. Name of News Paper JVVNL AVVNL JdVVNL (vi) Dainik Samachar Jagat 10.12.2015 - - (vii) Punjab Kesari 10.12.2015 - -

1.11. As directed by the Commission, the Petitioners made Audio-visual presentation at their head offices.

1.12. In all 933 numbers of comments/suggestions were received on JVVNL’s petition, 380 numbers on AVVNL’s petition and 175 numbers on JdVVNL’s petition from the individual consumers and organizations.

1.13. The Commission forwarded the suggestions/comments submitted by the

Stakeholders to the respective Discoms for giving reply. Discoms have sent their replies to them under intimation to the Commission.

1.14. Several of the Stakeholders raised question on admissibility of the petitions on

the ground that the petitions are incomplete and do not comply with the Hon’ble APTEL order dated 18.05.2015. Therefore, the Commission vide its letter dated 01.01.2016 sent some of such representations received from various Stakeholders to the Discoms for their comments. Jaipur Discom vide their letter dated 19.01.2016 submitted a reply. Before a decision could be taken on the question of admission, an Execution Petition no. 1 of 2016 came to be filed before the Hon’ble Appellate Tribunal, questioning the admissibility of the petitions. Therefore, the Commission decided to wait for the orders of Hon’ble Tribunal.

1.15. On dt. 18.02.2016, Hon’ble APTEL initially stayed further proceedings on the

tariff petitions filed by Discoms in the Commission. Rajasthan Discoms were also impleaded as parties to the execution petition. Discoms filed an Interlocutory Application (I.A.) no. 127 of 2016 for vacation of stay. Thereafter on 04.03.2016, Hon’ble APTEL on hearing the Counsel for Discoms, vacated the stay.

1.16. Hon’ble APTEL vide its order dt. 17.03.2016 ultimately dismissed the execution

petition with an observation that “After hearing all the parties, we find that at present, the Discoms have filed the relevant data in support of the said petitions which are now pending before the State Commission and the said data are sufficient for the purpose of deciding the said petitions”.

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1.17. Thereafter, the additional data furnished by Discoms was also placed on

websites of the Commission and Discoms. The Commission held public hearing of all the petitions on 25th, 26th and 27th of April, 2016. During the public hearing, persons listed at Annexure-1 made oral submissions.

Consideration of Preliminary Issues

1.18. During the course of hearing, Shri D.P. Chirania representing RSEB Retired Abhiyanta Evam Adhikari Jan Kalyan Trust, Shri G.L. Sharma and a few others raised a preliminary issue that petitions filed by the Petitioner Discoms have not yet been admitted by the Commission and therefore they could not be taken-up for hearing on merits. They also referred to the statement filed by the Commission before Hon’ble APTEL that it has not yet admitted the petitions but has only allowed the Distribution Companies to publish the Notices as required under Section 64(2) of the Act.

1.19. The Commission observes that it is well within its powers to get the notice published before considering the admission of petition and then decide on admission and hearing of the petitions based on the material placed before it. There is nothing illegal in this. The admission of a petition under Regulation 34 of RERC (Transaction of Business) Regulations, 2005 is not mandatory before issuance of notice in the tariff petition, as notice is to be published in tariff petition u/s 64(2) of the Electricity Act and not under the RERC (Transaction of Business) Regulations. Although, RERC (Transaction of Business) Regulations, 2005 and RERC (Terms and Conditions for Tariff Determination) Regulations, 2014 provide for admission of the petitions, it is a well accepted practice that admission and hearing of petitions on merits can be considered and decided together in the facts and circumstances of a given case.

1.20. In Appeal No. 255 of 2013 dated 01.02.2016, Hon’ble APTEL, while upholding

the order passed by the Delhi Electricity Regulatory Commission on the tariff of Delhi Transco Limited, has held that the Commission can consider shortfall in the submission of petition with the latest available data and audited accounts on its own and approve the ARR.

1.21. Hon’ble APTEL in Appeal No. 62 of 2015 and 63 of 2015 decided on 02.03.2016, while upholding the orders of Tamil Nadu Electricity Regulatory

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Commission which had determined tariff suo-motu, has held that inadequacy of required information can be provided later and the petitions may be considered pending furnishing of information.

1.22. In the present petitions, though initially the Discoms had filed petitions with

certain data gap/ lack of information, however thereafter, additional data/ information as required by the Commission has been filed.

1.23. The Commission, considering the filings made by the Discoms in the light of the provisions of Electricity Act, 2003 and Tariff Regulations, 2014 and various orders of Hon’ble APTEL including order dt. 18.05.2015 in Appeal No.16 of 2014 and the orders dt. 04.03.2016 and 17.03.2016 in EP No. 01 of 2016, has decided to admit the petitions filed by Discoms and pass orders on merit simultaneously.

1.24. During the course of hearing, it has been contended by some of the

Objectors that the petitions are of the year 2015-16 and as the year FY 2015-16 has ended, they have to be rejected without considering going into merits.

1.25. We have carefully considered the above point also.

1.26. It is not in dispute that the Discoms filed their petitions for True up of FY 2013-

14, ARR of 2015-16 and petition for approval of Investment Plan for the year 2015-16 on 15.07.2015. Thereafter, on 28.08.2015, Discoms filed amended petitions for True up for FY 2013-14, ARR, approval of Investment Plan and tariff for FY 2015-16. On scrutiny of the petitions, several deficiencies were found and these were required to be removed. Accordingly, inadequacies came to be removed in the course of pendency of these proceedings and this took time.

1.27. When notices of petitions were published under section 64(2), Shri D.P. Chirania and others raised questions on admissibility of the petitions and also filed an execution petition before the Hon’ble APTEL alleging that the petitions of the Discoms have been accepted by the Commission in violation of Hon’ble APTEL’s order dated 18.05.2015, and publication of the petitions under section 64(2) of the Electricity Act, 2003 was therefore illegal.

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1.28. Hon’ble APTEL initially stayed further proceedings before the Commission. However, subsequently, it vacated the stay on 04.03.2016. On 17.03.2016, ultimately Hon’ble APTEL dismissed the execution petition.

1.29. Thus, by the time the Commission could go ahead with the hearing of the main petitions on merits, financial year 2015-16 came to an end.

1.30. In this regard we may usefully refer to the orders of the full bench of Hon’ble

APTEL in Appeal No. 179 of 2012 dated 31.05.2013 in the case of Kerala High Tension and Extra High Tension Industrial Electricity Consumers’ Association, Kochi. In the said case, a question arose before Hon’ble APTEL as to whether the Electricity Act, 2003 or the tariff regulations permit for retrospective fixation of the tariff. Hon’ble APTEL, after examining the question at length held that there is no infirmity in the State Commission’s order in effecting the tariff retrospectively. The Hon’ble APTEL at para 74 has observed as follows:

“Let us now refer to findings of the full bench of the Tribunal dated 26.05.2006 in Appeal no. 4 of 2005 & batch in case of Siel Ltd. which has upheld the retrospective determination of tariff by the State Commission and which has been referred to by the Learned Counsel for the Respondent Board. The relevant findings are as under:

“77. Some of the Industrial Consumers have questioned determination of tariff by the Commission on the ground that the effect of the Tariff Order for the year 2005-06 was given from April 1, 2005 while the order was passed on June 14, 2005. According to them the Commission was not having any jurisdiction to require the consumers to pay enhanced tariff from a retrospective date. 78. In order to determine the reasons which led to the passing of the tariff order on June 14, 2005 instead of it being passed on March 31, 2005, it is necessary to refer to a few dates. The Board filed ARR and tariff application on December 30, 2004. The application, however, was found to be incomplete. The Commission by its communication dated January 21, 2005 asked the Board to remove the deficiencies and complete the application. It was, however, only on Feb., 9, 2005 that the deficiencies were removed and the application was taken on record. This led to delay in the determination of tariff for the year 2005-06. The Commission was able to pass the tariff order only on

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June 14, 2005, though the financial year commenced on April 1, 2005. 79. It is not in dispute that the Commission determined the tariff for the year 2005-06. The Industrial Consumers would not have been able to grudge the application of the tariff order with effect from April 1, 2005, in case the tariff order was passed on that date or on a date close to that date. It is only because the tariff order was delayed by about two months that the Industrial Consumers are finding fault with its application from April 1, 2005. 80. It needs to be noticed that the retrospective operation covers only a period of two months and having regard to the short time involved, the Commission was of the view that the interest of the consumers will not be adversely affected by the retrospective operation of the tariff order. 81. We do not find that the Commission was wrong in its approach by giving effect to the tariff order from the aforesaid retrospective date as the tariff was fixed for the tariff year 2005-06, which commenced on 1st April, 2005. If the submission of the Industrial Consumers is accepted, a consumer could initiate some proceedings in a Court against the Commission with a prayer for seeking an interim order restraining the Commission from revising the tariff on some ground or the other. This could delay the passing of the tariff order in case an interim order interdicting the determination of tariff is passed pending the proceedings. In such a contingency, it is only after the interim order is lifted by the Court that the Commission would be in a position to pass the tariff order. Obviously, it would only be just and fair that the tariff order relates back to and commences on the first day of the year for which the tariff determination is made. In Kanoria Chemicals & Industries Ltd. & Anr.Vs. State of U.P. & Ors. (1992) 2 SCC 124, a question was raised with regard to the competence of the Electricity Board to determine tariff with retrospective effect. The Supreme Court was of the view that retrospective effect to the revision of tariff was clearly envisaged in law. In this regard, the Supreme Court held as follows: “A retrospective effect to the revision also seems to be clearly envisaged by the section. One can easily conceive a weighty reason for saying so. If the section were interpreted as conferring a power of revision only prospectively, a consumer affected can easily frustrate the effect of the provision by initiating proceedings

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seeking an injunction restraining the Board and State from revising the rates, on one ground or other, and thus getting the revision deferred indefinitely. Or, again, the revision of rates, even if effected promptly by the Board and State, may prove infructuous for one reason or another. Indeed, even in the present case, the Board and State were fairly prompt in taking steps. Even in January 1984, they warned the appellant that they were proposing to revise the rates and they did this too as early as in 1985. For reasons for which they cannot be blamed this proved ineffective. They revised the rates again in March 1988 and August 1991 and, till today; the validity of their action is under challenge. In this State of affairs, it would be a very impractical interpretation of the section to say that the revision of rates can only be prospective”. 82. Section 62, which provides for determination of tariff by the Commission, does not suggest that the tariff cannot be determined with retrospective effect. In the instant case, the whole exercise was undertaken by the PSERC to determine tariff and the annual revenue requirement of the PSERB for the period April, 1, 2005 to March 31, 2006; therefore, logically tariff should be applicable from April 1, 2005. 83. According to sub-section (6) of Section 64 of the Act of 2003, a tariff order unless amended or revoked continues to be in force for such period as may be specified in the tariff order. Thus the Commission is vested with the power to specify the period for which the tariff order will remain in force. The Commission deriving its power from Section 64(6) has specified that the order shall come into force from April 1, 2005. No fault can be found with such a retrospective specification of the Commission. 84. The learned counsel for the industrial consumers relied on the decision of the Supreme Court in Sri Vijay Lakshmi Rice Mills vs. State of Andhra Pradesh, AIR 1976 SC 1471, wherein it was held that a notification takes effect from the date it is issued and not from a prior date unless otherwise provided by the statute, expressly or by appropriate language from which its retrospective operation could be inferred. This decision is of no avail to the industrial consumers, in view of the provisions of Section 64 (6) of the Act of 2003, which empowers the Commission to specify the period for which the tariff order will remain in force. In other words, the Commission is empowered to specify the date on which the tariff order will commence and the date on which it will expire.

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85. The Board in consonance with the cost plus regime is entitled to recover all costs prudently incurred for providing service to the consumers. Besides, the Board is entitled to reasonable return. Since the cost prudently incurred has to be recovered, therefore, in the event of the tariff order being delayed, it can be made effective from the date tariff year commences or by annualisation of the tariff so that deficit, if any, is made good in the remaining part of the year or it could be recovered after truing up exercise by loading it in the tariff of the next year. All these options are available with the Commission. 86. There is one more aspect which needs to be considered. In case the Commission had lowered the tariff rates, relief to the consumers could not be denied on the ground that the tariff order is being operated retrospectively. 87. For all these reasons we hold that the Commission had the jurisdiction to pass the tariff order with retrospective effect. Therefore, we reject the submission of the learned counsel for the industrial consumers that the tariff cannot be fixed from a retrospective date.

1.31. In the Commission’s view, the above judgment applies to the present case squarely and with equal force.

1.32. The petitioners first filed true up and ARR petitions on 15.07.2015 and thereafter filed petition for tariff determination for FY 2015-16 on 28.08.2015. The gaps found in these petitions had to be filled up by the Discoms at the instance of the Commission which took some time. When the Commission was about to proceed further in the matter the execution petition referred above came to be filed before Hon’ble APTEL and by the time Hon’ble APTEL decided the petition the financial year 2015-16 came to an end. The Commission in the facts and circumstances is of the view that mere end of financial year 2015-16 cannot be a ground for non-consideration and rejection of the petition. The Commission, in law has to consider the petitions and decide them on merits.

1.33. Now taking up the petitions on merits, the Commission has carefully

considered the submissions made in the petitions and the material placed in support of the same, the objections or views filed by the Stakeholders and

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the reply filed by the Discoms thereto as well as the orders of Hon’ble APTEL.

1.34. The Commission has also considered the reply given by the Discoms to the queries of the Commission, and oral submissions made by the Petitioners and Stakeholders during the hearing and also perused all the relevant records while finalizing this order.

1.35. The Commission while passing this order has also taken into consideration the UDAY Scheme framed by GOI with consent of GoR and measures to be taken under the same.

1.36. As issues arising in all the petitions are common for all three Discoms and the

Stakeholders have also made common submissions on all the petitions and a common hearing was held in the matter, the Commission therefore has decided to consider all the petitions together and dispose them through this common order.

1.37. The projections approved in this order for Generation and Transmission is for

the purpose of estimating the Aggregate Revenue Requirement of the Petitioners. It shall not be construed as formal approval of the Commission for any investment or tariff for transmission or generating plant, etc.

1.38. For ready reference, a list of abbreviations used in this order is placed at

Annexure – 2 of this order.

1.39. All energy unit figures used in this order, unless stated otherwise, are in Million Units (MU).

1.40. For the purpose of representation, figures given in the tables are shown as

rounded off. However, for calculation purpose, actual figures have been considered.

1.41. This order has been structured in seven sections as given under:

(i) Section 1 - Filings, preliminary issues (ii) Section2 - Comments/suggestions of Stakeholders, Petitioners’ response

and the Commission’s directives/observations thereon (iii) Section 3 - True-up of ARR for FY 2013-14 of the three Discoms

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(iv) Section 4 - Investment Plan for FY 2015-16 of the three Discoms (v) Section 5 - Annual Revenue Requirement (ARR) for FY 2015-16. (vi) Section 6 - Tariff proposals and orders thereon of the Commission (vii) Section 7- Review of Directives and compliances thereof.

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Section – 2 Stakeholders comments/suggestions, Petitioners’ response and the Commission’s views: Large numbers of objections and views have been filed by the consumers. Some of them made very relevant points for consideration and some are general in nature. The Commission has looked into and considered each point raised by the Stakeholders and reply given by Discoms while issuing the order. The issue wise submissions of the Stakeholders and Petitioners are discussed in six parts as under: (1) Part I - General issues/comments related to True-up of FY 2013-14 (2) Part II – Issues/comments related to True up of ARR of FY 2013-14 (3) Part III - Issues/comments related to Investment Plan of FY 2015-16 (4) Part IV - General issues/comments related to ARR & Tariff of FY 2015-16 (5) Part V - ARR related issues/comments (6) Part VI - Tariff related suggestions/observations.

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Part I – General issues/comments related to True-up of FY 2013-14

The following are the views expressed by the Stakeholders made both through written /oral submissions

2.1. Incomplete data and information 2.1.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that various formats to be furnished with petition are either

incomplete or information was not fully furnished. Therefore, as per the APTEL order dated 18.05.2015, the petition cannot be accepted.

2. It was submitted that the JVVNL and AVVNL, in the formats attached with petitions, have stated that “Information gathered and shown to the best possible extent. Some information is missing due to non-availability of specific data at present”. In this respect Discoms are requested to supply the following information:

I. Discoms may indicate the specific data which is not available at present. II. When the data as provided are not complete, how they are seeking true-

up finalization?

2.1.2. Petitioners’ Response:

In response to above, the Discoms submitted that all the requisite data pertaining to determination of True up, ARR and Tariff along with the Annual Audited Accounts have been submitted as per Tariff Regulations. They further submitted that the data submitted is as per the audited accounts and Discoms prayed to consider the formats and the petitions and additional submissions in totality. 2.1.3. Commission’s view:

1. The Commission observes that while filing any petition the Discoms shall ensure

all the required data is filed along with the petition in its support. This will save valuable time and help the Commission in taking expeditious decision.

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2. This issue of filing of the petition with incomplete data and information has been dealt by the Commission in the Section 1 of this order. 2.2. Audited Accounts 2.2.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the audited accounts of JVVNL contain an adverse

opinion “that the financial statement do not give a true and fair view in conformity with the accounting principles generally accepted in India.” In such a situation, how Discom has filed the true up petition based on accounts which are not true and fair. It was suggested that Audit of Accounts for FY 2014-15 may be got conducted by a competent third party /agency to be appointed by the Commission which may also check the Audited Accounts for FY 2012-13 and FY 2013-14. The Commission should also take action against Discom in view of adverse opinion of CAG.

2. Whether the data placed in true-up petition, presented as “Actual/Audited” in respect of expenditure/revenue, is of actual expenditure and revenue receipt or these are on accrual/assessment basis? In case these are on accrual/assessment basis then the data on actual basis may be supplied.

3. The audit of books of accounts of the three Discoms was completed by the Chartered Accountant and by the CAG on different dates in the months of October 2014 to January 2015. Therefore, the Discoms should have filed the true up petition by January or February 2015. The Discoms must furnish the reason of delay in filing the petition. 2.2.2. Petitioners’ Response:

1. In response to above, JVVNL submitted that the adverse opinion referred to by

the Stakeholders pertains to the accumulated losses of Rs. 2335.34 crores, which is shown as revenue subsidy receivable from the State Government under non-current assets and against revenue gap. According to the Auditor, this was in contravention to Accounting Standard – 12 “Accounting for Government Grants” and therefore, the losses had been understated. The Discom also submitted that appropriate explanation has been provided in the annual accounts for FY 2013-14 on Page No. 128. Also, clarification regarding the depiction of the accumulated losses as revenue subsidy receivable from the

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State Govt. was sought by CAG and after due consideration of the facts, CAG vide their letter No. 780 dated 1st July 2015 approved the methodology being followed by the Discom. It is also submitted that the same Statutory Auditor has certified the financial statements for FY 2014-15, depicting true and fair state of affairs. Accordingly, keeping in view the acknowledgement given by the Auditor, it is evident that annual accounts present a true and fair picture of the financial position of JVVNL for FY 2013-14.

2. The data placed in True-up portion of the petition in respect of expenditure and

revenue and also shown in Table 1 of the petition are as per the annual audited accounts, which are on accrual and assessment basis. The petitions for True-up have been filed in accordance with Tariff Regulations, which clearly states that True up of previous year’s expenses and revenue shall be based on Audited Accounts.

3. The order on True-up of FY 2012-13 was issued on 20th February 2015, therefore the question of filing petition for True-up of FY 2013-14 by January or February does not arise, as after the issuance of order, Discoms reviewed the order, considered the impact of various decisions /directives and took necessary steps before preparation of fresh petition for True-up of FY 2013-14. Current petitions for True-up have been filed along with the petitions for determination of Tariff for FY 2015-16.

2.2.3. Commission’s view:

1. The Commission has noted that the Discoms in compliance to Tariff Regulations

have furnished the audited accounts for FY 2013-14, i.e., the year for which true up is to be carried out. As regards audit to be done by a third agency the Commission observes that Discoms are Government Companies registered under Companies Act. The Companies Act specifically provides for the auditing to be done both by a Statutory Auditor and Comptroller & Auditor General. Therefore, once audit of the Company has been carried out in accordance with Law there is no question of further getting them audited by any other authority.

2. The Commission observes that comments of CAG, made on the accounts have

to be addressed by the Discoms. If Statutory Auditor or CAG is not satisfied with reply to observations, the same has to be dealt further as prescribed in the

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relevant law. Therefore, question of Commission taking any action in this regard does not arise. 2.3. Connected load 2.3.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that in the case of JVVNL, in the true-up petition of FY 2012-13,

the total number of flat rate agriculture consumers was 60223 with connected load of 321063.5 KW whereas, in the current true up petition of FY 2013-14, the total number of flat rate agriculture connection has been shown as 55990 consumers with connected load of 396276 KW. Discoms are required to justify such increase in connected load with reduction in number of consumers.

2. It was submitted that in the case of JdVVNL, in the true-up petition of FY 2012-13

the total number of metered agriculture consumers was 207797 with connected load of 4228657 KW, whereas, in the current true-up petition for FY 2013-14, total number of metered agriculture consumers has been shown as 231996 with connected load of 3661524.46 KW. Discom is required to justify such reduction in connected load with increase in number of consumers. 2.3.2. Petitioners’ Response:

1. In response to above, JVVNL submitted that with ever decreasing ground water level, the connected load per consumer is bound to increase. The same trend has been observed by the Stakeholders.

2. The Stakeholders seem to have considered the connected load of metered

agricultural consumers for FY 2012-13 in kW whereas the connected load has been provided in HP. On correctly considering the units of the connected load, it can be seen that the connected load for agricultural metered consumers shows an increase in FY 2013-14 over FY 2012-13.


The Commission has noted that the Discoms have clarified the query of the Stakeholders.

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Part II – Issues/comments related to True-up of ARR of FY 2013-14 2.4. Revenue 2.4.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the figures of approved revenue from sale of power at Table number 1 of the petitions and revenue as approved by the Commission in its order date 06.06.2013 seem to be different. The Discoms may clarify the same.

2. There has been no category of consumer as Public Water Works (S), Public Water Works (M) and Public Water Works (L) but in form no. 2.1 of the petition, these new categories have been shown. Discoms are required to explain the same.

3. In form no. 2.1, an amount of fuel surcharge has been shown by each Discom. It is not clear as to which period and for which quarter of the financial year these amounts relate. Discoms may intimate the same. Further, copy of notification issued by each Discoms in respect of fuel surcharge in question may be supplied.

4. In form no. 2.1, an amount against ‘Adjustment of past billing’ has been shown. Discoms may supply the information as on what account and for which period such amount relates.

5. In form no. 2.1 of JVVNL, an amount against “theft & misuse” against each category of consumers has been shown. Discom may furnish the quantum of energy assessed in each category of consumer on account of theft and misuse.

6. Discoms may clarify whether the amount of revenue as shown in form No. 2.1 is actually received or is as per assessment only.

7. In form no. 2.1 in respect of BPL, small domestic and agriculture category, each Discom may clarify whether the amount shown as revenue against these categories is after allowing subsidy or before.

8. The fixed charges and energy charges in respect of flat rate consumers for FY 2013-14 are not matching with the connected load and No. of consumers as well. Discom is requested to supply full details of calculations of these figures.

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9. In form no. 2.1, the amount of DPS/LPS recovered from each category of

consumers during FY 2013-14 has not been mentioned. This may now be intimated. The DPS/LPS charges are part of tariff and hence form the revenue from sale of power.

10. In case of small domestic category, when revenue is computed using the approved tariff rate, it comes out to be on the higher side than the actual revenue shown. Discoms may clarify the same.

11. Variation in approved and actual per unit charges needs to be explained. 2.4.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that the Stakeholders have considered the revenue approved by the Commission at revised tariff for the entire year, whereas the Discoms have considered the revenue approved by the Commission considering the impact of revised tariff for the remaining part of the year only as tariff was not applicable for the entire year.

2. The tariff applicable for Industries and Public Water Works is the same. The Commission in its previous Tariff Orders also acknowledged these categories while determining the revenue. As Public Water Works is a large government sector consumer and caters to the welfare of general public, therefore, for ease of monitoring and to assist the government departments in getting the required information, such segregation has been adopted.

3. Regarding fuel surcharge, the Discoms submitted that the amount of Fuel Surcharge for FY 2013-14 as shown in Form 2.1 is computed as per the Regulation 127 of the RERC Tariff Regulations, 2009 and is levied on quarterly basis after duly notifying the consumers through orders published by the distribution licensees. The copy of the order is also made available to the consumers on the respective websites of the Discoms.

4. Regarding adjustment of past billing, the Discoms referred to the adjustment of debit/credit given to the consumers on account of various reasons like audit charges, average charges, wrong billing, etc. which does not pertain to the current month billing but is related to earlier period.

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5. JVVNL submitted that the quantum of energy assessed on account of theft has

been accounted for in the energy sold to that category of consumers. In addition, there is no energy assessed in case of misuse and the only amount recovered is based on tariff difference. The revenue shown in the column of Theft & Misuse is exclusive of compounding charges as these are paid to the Government but includes the amount of civil liability.

6. The Discoms submitted that the data placed in True-up Petition in respect of revenue and expenditure and also as shown in Table 1 of the Petition are as per the Annual Audited Accounts, which is on accrual and assessment basis.

7. The Discoms submitted that the revenue as shown in Form No. 2.1 for BPL and small domestic category is on the basis of amount assessed (i.e., gross amount) which means that the tariff subsidy received from the Government is included in it.

8. The Discoms submitted that it is important to note that the revision of tariff was not applicable for the entire year, therefore, the calculation of energy charges done by the Stakeholders will not exactly match the approved tariff. Although the tariff order was issued after 2 months of start of the financial year, i.e., June, the full impact of revised tariff is seen approximately after two months of the issue of the tariff order due to meter reading and billing cycle.

9. Regarding DPS/LPS, the Discoms submitted that the DPS/LPS recovered from the consumers are treated as other operating income and the same have been shown as a part of Non-Tariff Income in the True up Petition and formats.

10. In case of fixed charges for domestic consumers, total number of consumers as shown is that at the end of the year. Therefore, the calculation of total fixed charges as computed will not give a fair picture as there are consumers which have been added during the year also and the fixed charges would be applicable from the date of connection only for such consumers. In addition, the revision of tariff was not applicable for the entire year, therefore the calculation of charges done by the Stakeholders/ Objectors will not exactly match with the approved tariff. Although the tariff order was issued after 2 months of start of the financial year, i.e., June, the full impact of revised tariff is seen approximately after two months of the issue of the Tariff Order due to

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meter reading and billing cycle. Again, it is submitted that the total number of consumers includes the disconnected consumers (DC) also which have not been converted into Permanent Disconnected Consumer and their billing is stopped from the date of DC. In addition, the number of consumers mentioned in Form 2.1 for FY 2013-14 include PDC consumers.

11. With regard to the variation in approved and actual per unit charges, the Discoms submitted as follows:

a) The revision of tariff was not applicable for the entire year, therefore, the calculation of charges done by the Stakeholders will not exactly match the approved tariff. Although the tariff order was issued after 2 months of start of the financial year, i.e., June 2013, the full impact of revised tariff is seen approximately after two months of the issue of the tariff order due to meter reading and billing cycle.

b) That the figures of energy sales were approved on the basis of projection. The energy sale to those consumers who get disconnected during the year does not get reflected in the same. Such consumers have availed and used the energy but the corresponding bills have not been deposited and they have been disconnected. In other words it can be said that the energy of Discoms has been billed but revenue has not been realized which results in lower per unit realization.

c) In domestic category in the rural areas, another 10% rebate is being given to the consumers. This further leads to a variation in the approved and actual per unit charges.

d) The Stakeholder seems to have not considered the fact that the approved billing rate as used for calculations is based on the estimated consumption in different slabs across categories whereas the actual consumption may vary across different slabs. It is a common phenomenon that the consumption pattern of the consumers does not remain the same over the year.

e) It also happens that a consumer having consumption between 150-300 units in one billing cycle may have a consumption of over 300 units in the other billing cycle. So there might be a variation in the slab wise

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consumption but the category wise total does not change. So the impact of the same has to be given due consideration while comparing the actual and approved figures.

f) In case of agriculture category, the load is as on March 31st, 2014. It does not present a clear picture of the variation in load over the year, which does not remain constant. Some consumers get their load revised which also causes a variation in the per unit charges thus calculated.


The Commission has taken note of the comments of the Stakeholders and reply of Discoms thereto. Further, with regard to the higher or lower per unit revenue under certain categories, the Commission has dealt with the same under the heading Notional Revenue in the true up analysis section 3 of this order.

2.5. Distribution Losses 2.5.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that in case of JVVNL, AVVNL, JdVVNL, the distribution losses for FY 2013-14 have been 27.85%, 20.69% and 22.45% respectively. No reasons for such high losses have been mentioned. Therefore, in the absence of any reasons for such high losses, Commission may kindly consider for distribution losses as per trajectory approved.

2. It was submitted that the three Discoms have indicated the average losses of 24% in FY 2013-14 against the approved losses of 18% which is alarming. It was suggested that Audit of Accounts for FY 2014-15 may be got conducted by a competent third party /agency to be appointed by the Commission which may also check the Audited Accounts for FY 2012-13 and FY 2013-14. 2.5.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that the increase in losses is due to increase in theft, change in methodology for billing of agriculture consumers having defective meters and due to shift of HT consumers to open access. To reduce theft, the Discoms have taken numerous steps including increase in

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vigilance and spreading consumer awareness. Therefore, the Discoms have requested to the Commission to consider the efforts being made by the Discoms.

2. With regard to audit, the Discoms have submitted that audit of accounts is done in accordance with the statutory and industry practices. 2.5.3. Commission’s view:

Commission has considered with seriousness the issue of higher distribution losses. The same has been specifically dealt in UDAY Scheme also. The increase in losses should really be a concern for Discoms as it is directly affecting their working and finances. Unless serious efforts are made to bring in the losses to the targeted level, the Companies cannot turn around the corner more so the financial crisis which they are facing at present. The Commission cannot approve the impact of the higher losses on the consumers. Therefore, to give a message to the Discoms that their inefficiencies cannot be condoned, the Commission desires to stick to loss trajectory target given by it earlier. 2.6. Power Purchase Expenses 2.6.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the RGTPS unit III (1*110MW GT) was synchronized on

20.03.2013, the CTPP unit III was synchronized on 14.09.2013 and the Kalisindh unit of RVUN was synchronized on 17.09.2013.These plants had supplied infirm power but in form no. 3.1 for FY 2013-14, no power purchase units have been shown against these plants. Discoms may clarify the same.

2. It was submitted that in form 3.1, the Discoms have not shown the rate of charge separately for fixed and energy charges for FY 2013-14.

3. It was submitted that the Commission has finalized the true up of RVPNL for FY 2013-14 vide order dated 14.08.2015, but in form 3.1 of FY 2013-14, the Discoms have not considered the impact of that.

4. In case of RVUN generating units, the rates of power purchase are not matching with those allowed by the Commission.

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5. In case of RVUN generating units, if the PLF is lesser than the normative, then the capacity charges are to be proportionately reduced and such charges are required to be shown in the form accordingly. Hence, the form no. 3.1 may please be got revised and the revised form be supplied.

6. Clarification and age wise breakup of “prior period expenses” as shown in form no. 3.1 under various heads of power purchase sources has been sought.

7. The tendency of purchasing the costlier electricity to meet the gap of demand and supply should be avoided.

8. It was submitted that Discoms may furnish the reasons for purchasing costly power from generating station of the State while cheaper power was available through open market/power exchange.

9. It was submitted that Discoms have violated the observation made by the Commission on ‘Short term power purchase’ as discussed by the Commission under Para 7.3.7.5.1 of Section 3 of its order dated 06-06-2013 by way of indulging in regular extra purchases at higher cost, even by backing down of the State run power plants. 2.6.2. Petitioners’ Response:

1. The Discoms have submitted that purchases from above power plants have

been considered and details are provided to the Stakeholder.

2. Energy charges and capacity (fixed) charges have been separately mentioned in Form No. 3.1 submitted to the Commission.

3. The Discoms submitted that the impact of True-up of RVPNL on transmission charges has already been accounted.

4. The Discoms submitted that the capacity charges and energy charges indicated in the power purchase statement are as per the bills raised by the generating stations. It is important to note that any adjustment on account of various factors like fuel charges, insurance expense, adjustments, etc. made by the generating stations are also reflected in the bills raised and therefore, the charges per unit will not exactly match the tariff approved by the Commission.

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5. Regarding reduction of fixed charges, the Discoms submitted that any

adjustment on account of lower PLF has already been taken into account.

6. Regarding prior period expenses, the Discoms submitted that the prior period expenses relate to adjustments made to the bills raised by the generating companies in the past. Auditor has already scrutinized and verified such details during the audit of financial statements. Age wise breakup of prior expense is really voluminous and hefty chunk of data containing the year long details of transactions which will not be feasible to be provided at the moment. Also, all the requisite data pertaining to the determination of true up have been provided as per the Regulations.

7. Discoms submitted that during the extreme shortage of electricity, the power is purchased from the exchange at the prevailing rates.

8. Discoms submitted that in order to meet the power requirements of the consumers, the Discoms have to make long term agreements with generating companies. Such agreements have to be upheld. The power market/exchange is volatile and cannot be relied upon as a constant source for power procurement. However, the Discoms undertake due diligence to ensure that merit order despatch is followed while backing down power from its long term sources and to gain maximum benefit out of lower cost power available in the exchange.

9. Discoms submitted that power procurement is based on a dynamic demand supply scenario and the same is linked to grid frequency and various other factors. The Discoms ensure that during the power purchase procedure, merit order dispatch principle is followed. Also, UI has to be carried to maintain grid stability and the Discoms are following the best practices to ensure that the impact of UI is kept to a minimum. 2.6.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and reply of Discoms thereto and has dealt with this issue in section 3 of this order.

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2.7. O&M Expenses 2.7.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that Discoms have shown O&M expenses in Table 1 of their

petition in a combined form, whereas as per regulation 83 of RERC Tariff Regulations, 2009, these should have been shown separately in respect of employee expenses, A&G expenses and R&M expenses.

2. It was submitted that the employees’ expenses include the provisions of superannuation board contribution, gratuity fund contribution, etc. In such circumstances, how the employee’s expenses can be said as actual one.

3. Under A&G expenses, the Discoms have shown other miscellaneous expenses. Each Discom may furnish the detail of these other miscellaneous expenses.

4. Under A&G expenses, JVVNL has shown a sum of Rs. 2.20 crore and Rs. 15.36 crore towards bill collection charges and spot billing expenses. These expenses are part of employee expense not of A&G expense.

5. It was submitted that expenditure towards CFL distribution has been shown under other charges. As far as is known, CFL has been distributed with cost charged from consumers in lump sum or in instalments and as such this sum is not chargeable for truing up.

6. It was submitted that JVVNL has stated that increase in establishment cost is due to implementation of Sixth Pay Commission recommendations. Sixth Pay commission recommendations have been implemented by order dated 01.10.08. JVVNL should have petitioned for revision in norms with data and until norms are revised, this is to be considered as per regulations.

7. JVVNL in form no. 3.2 has shown a sum of Rs. 11.03 crore in respect of “expenditure on sale of power IEX and Th. PXIL (Tr. C)”. Discom may clarify as to for what purpose these charges have been incurred.

8. It was submitted that there is abnormal increase in O&M Charges as compared to approved charges which is unacceptable.

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1. In response to above, the Discoms submitted that the breakup of O&M expense has been provided in accordance with the Regulations. The charges are as per the annual audited accounts.

2. The expenses towards provision for superannuation board contribution, gratuity fund contribution, etc. are all part of employee expenses. Provisions made have been treated as expense in line with the accounting principles.

3. The other miscellaneous expenses are, as the name suggests, expenses made towards miscellaneous activities. These are audited figures which have been duly verified by the Auditor and as such require no further explanation. Some of the expenses that are included in the miscellaneous expenses are printing and stationary expenses, advertisement expenditure, examination expenses, testing charges, expenses on HT reading by outside agencies, etc.

4. The work of billing and cash collection has been outsourced and the expenses incurred on the same have been booked accordingly under Administrative and General Expenses. It is pertinent to mention that wherever billing and bill collection is done by the Discom employees, the payment on account of salary and allowances is booked as employee cost.

5. The CFL expense was incurred by the Discoms towards procurement and distribution of CFL. The Government provided subsidy against the same, which has been shown under the head of subsidy received. Therefore, while preparing the petition for True-up, only the net impact of such expenses has been considered.

6. JVVNL submitted that the increase in establishment cost is due to inflationary increase as well as regularization of employees who were earlier on probation.

7. JVVNL submitted that the charges pointed out by the Stakeholder in Form No. 3.2 are towards the operating charges, transaction charges, application charges, etc. for PXIL, NLDC application fee, CTU transmission fee, NLDC scheduling fee, etc. for IEX.

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8. O&M expenses as submitted in the True up petition are as per the actual and as shown in the annual accounts of the Discoms which have been duly audited by the Statutory Auditor. Increase in employee cost is due to inflationary increase as well as regularization of employees who were earlier on probation. Expenses towards provision for superannuation board contribution, gratuity fund contribution, etc. are all part of employee expenses. Provisions made have been treated as expense in line with the accounting principles. These are audited numbers, which, have been duly verified by the Auditor and as such requires no further explanation. 2.7.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and reply of Discoms thereto and has approved the O&M expenses as per norms prescribed in the RERC Tariff Regulations, 2009. 2.8. Terminal Benefit 2.8.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the terminal benefit is to be allowed only to the extent the

actual payment has been made to the fund.

2. The copy of actuarial valuation report has been sought. 2.8.2. Petitioners’ Response:

1. In response to above, the Discoms have submitted that the provision for terminal benefits is being made in the financial statements as per the accounting practices. The actual payment towards terminal benefits in FY 2013-14 was Rs. 411.50 Cr for JVVNL, Rs. 181 Cr for AVVNL and Rs. 105 Cr for JdVVNL.

2. The detailed actuarial valuation report has been submitted along with the reply.


The Commission has allowed the expenses towards terminal benefit only to the extent of actual payment made to designated fund.

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2.9. Interest on Loan 2.9.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that in case of JVVNL, net fixed assets, equity and long term

loan (LTL) at the end of FY 2013-14 were Rs. 9414 crores (vide form 3.6 PY), Rs. 3586 crores (vide form 3.8) and Rs. 6551 crores (vide form 3.7) respectively. Thus, LTL utilised for the creation of assets were Rs. 5828 crores (Rs. 9414 crore less Rs. 3586 crores), which is less than the long term loan of Rs. 6551 crore. The proportionate interest on long term loan (LTL) of Rs. 5828 crores, that is Rs. 699 crores (= 786 x 5828/6551) is only admissible for tariff determination.

2. It was submitted that the short term loans (STL) and bonds are to be considered

to the extent of cumulative losses of Rs. 10,586 crores, Rs. 10401 crore and Rs. 10,221crore of JVVNL, AVVNL and JdVVNL respectively as per truing up order dated 20.02.2015 for FY 2012-13.

3. It was submitted that the interest on short term loan, interest on bonds and

finance charges and lease rental are very much higher than that approved by the Commission and Discoms have not given reasons for high variations.

4. It was submitted that the interest on the loan taken is due to inefficiencies and the receivables from GoR, which are in no way the expenses on normal distribution business. 2.9.2. Petitioners’ Response:

1. In response to above, the Discom submitted that while raising the objection, the Stakeholder has not considered amount towards capital work in progress (CWIP) and inventory. The unutilized amount of long term loan pointed out by the Stakeholder is used towards CWIP and Inventory.

2. Discoms have presented the true position with respect to interest on short term loans to the Commission. The actual expenses incurred on interest and finance charges as per the audited accounts have been presented in the True-up petition. The Discoms submitted that they had to resort to short-term loans in order to bridge the revenue gap over the years and the Discoms prayed to the Commission to consider the same.

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3. Non revision of tariff on timely basis led to wide gap between costs and revenue and has been one of the major reasons for the financial distress of the Discoms. The Discoms had to substantially increase short term borrowings to fund the rising revenue deficit. This increase resulted in sharp increase in cost of borrowings leading to a significant share of interest cost in the total cost. Non revision of tariff on time will lead to further increase in the interest costs, which will ultimately burden the consumers in the future. 2.9.3. Commission’s view: The Commission has taken note of the comments of the Stakeholders and reply of Discoms thereto and has dealt with this issue in section 3 of this order. 2.10. Depreciation 2.10.1. Stakeholders’ Suggestions/Comments

1. It was submitted that the Discoms have no proper and regular assets register.

Depreciation is being claimed by them on an arbitrary basis.

2. As per regulation 23(4) of RERC Tariff Regulations, 2009 read with its proviso “every Generating Co./Transmission Co./Distributing licensee has to segregate the fixed assets in two parts, i.e., assets which have completed 12 years period from date of their commercial operation and the assets which have not completed such period”. Discoms have not supplied such information.

3. From the reading of the accounts, it is noted that material cost is booked to CWIP even for those material which are lying at site. No date of commissioning of the assets is available with them. In such circumstances, there is no authenticity of assets added during the year.

4. It was submitted that the Discoms may also clarify whether in the gross value of assets, cost of newly installed meters and replacement of meters has been added or not.

5. It was submitted that in case of JVVNL at Table no. 1 and at Table no. 13, the depreciation has been shown as Rs. 426.55 crore whereas in their Accounts at Schedule 30 (page 112 of A/C books), it is only Rs. 398.13 crore. Discom is to clarify the same.

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6. It was submitted that to justify the increase in depreciation as compared to that

approved, simply writing that the difference is on the account of prior period expenses of depreciation under provisions is not sufficient. 2.10.2. Petitioners’ Response:

1. In response to above, Discoms submitted that the work of preparation of fixed assets register and other allied works for the year 2000-01 to 2012-13 has been outsourced to M/s Ankit Maheshwari & Associates, Jaipur which is under progress. The same has been mentioned in the annual audited accounts also.

2. Due to the non-feasibility of segregation of assets allocated in the transfer scheme to successor entities, the depreciation on assets of the Company as on 19.7.2000 has been calculated and incorporated in the books of accounts based on information provided by RVPNL.

3. Capital work in progress includes material issued for capital work and lying at site in terms of accounting policy adopted by the Company and the same is not transferred to the fixed assets block. Only those assets which are completed during the year are transferred to the fixed assets.

4. That the value of defective/burnt transformers is reduced for computation of gross fixed assets. The Cost of newly installed meters and replacement of burnt/defective meters has been charged to the respective consumers, hence not included in the value of gross assets.

5. That the detailed explanation regarding the difference of depreciation amount of Rs. 426.55 crore as per Schedule no 12 (Table nos. 1&13 of the petition) and that of Rs. 389.13 crore at Schedule no. 30 has been explained at 12.6 of the notes to accounts.

6. That the amount of depreciation as shown in the True up petition is on the basis of actual reflected in the annual audited accounts and Discoms requested the Commission to take an appropriate view on the same and approve it.

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2.10.3. Commission’s view: The Commission has taken note of the comments of the Stakeholders and reply of Discoms thereto and has dealt with this issue in section 3 of this order. 2.11. Subsidy 2.11.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that in case of JVVNL, the form 2.5 indicates receipt of subsidy of Rs. 1641 crores for FY 2013-14 but calculations of subsidy actually required has not been given.

2. It was submitted that the subsidy from Government should be received on time and non receipt of subsidy from Government is not to be passed on to the consumers. 2.11.2. Petitioners’ Response:

1. In response to above, the Discom submitted that the subsidy assessed for FY 2013-14 was Rs. 1306.36 crore against which a subsidy of Rs. 1641 crore was received from the Government. This implies that excess subsidy has been received by the Discom in FY 2013-14.

2. Discoms submitted that the subsidy amount due from government is received

on time.

3. During the public hearing, the Chairman, Discoms stated that Discoms are getting full amount of tariff subsidy from the Government and last year they got little more than what was committed.

2.11.3. Commission’s view: Commission while taking note of the reply given by Discoms observes that the payment of subsidy shall always be in accordance with the Provisions of Electricity Act, 2003 and the Regulations prescribed in this regard.

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2.12. Security Deposit 2.12.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the interest on security deposit of consumers has been on lower side for FY 2014-15. The Commission may kindly ensure payment by JVVNL of interest charges on security deposit to the consumers as per provisions of Sec. 47(4) of the Electricity Act, 2003.

2. It was submitted that the Discoms increase and levy the increased security deposit with increase in average consumption but do not refund or adjust it with reduction in consumption or load demand. It is also not a consumer welfare practice. 2.12.2. Petitioners’ Response:

1. In response to above, the Discom submitted that Interest on security deposit of consumers is being paid as per the provisions of the Regulations and Terms and Conditions of Supply. The Discom submitted that figures for FY 2014-15 are provisional.

2. Security deposit is being charged and adjusted as per the provisions of the Supply Code. In case of any discrepancies observed by the Stakeholder, he may inform about the same in Grievances Redressal Forum. 2.12.3. Commission’s view:

1. The Commission observes that the Discoms shall have to act according to the

provisions of Electricity Act, 2003 and the related Regulations framed by the Commission strictly and shall not give room for any grievance in this regard.

2. The Commission desires that at the end of every financial year the Discoms may furnish the details of statement of accounts to the consumers duly indicating the consumption, date of payment and amount thereof, the security held and interest payable and when it was paid , additional security, if any, required and due date of the same.

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2.13. Other Debits 2.13.1. Stakeholders’ Suggestions/Comments:

It was submitted that under other debit head, expenses of distribution of CFL, theft of fixed assets, bad and doubtful debts, rebate on tariff to new industries and prior period expenses have been shown. Such expense cannot form part of ARR and as such are not admissible. 2.13.2. Petitioners’ Response:

1. Regarding CFL, Discoms submitted that the CFL expense was incurred by the

Discoms towards procurement and Distribution of CFL. The Government provided subsidy against the same, which has been shown under the head of subsidy received. Therefore, while preparing the petition for True-up, only the net impact of such expenses has been considered.

2. Regarding theft of fixed assets, the Discom submitted that amount shown

against theft of fixed asset is the amount not recoverable through insurance as there is no insurance for fixed assets which are in the field.

3. Regarding bad and doubtful debts, the Discoms submitted that as per the policy of the Discoms, provision for doubtful debts is made equivalent to 50% of outstanding dues of permanently disconnected consumers which is as per the Accounting Policies and duly verified by the Statutory Auditor.

4. Regarding rebate, the Discoms submitted that the provision for rebate is already given in the tariff schedule and is accordingly being provided to the HT consumers, new industries and consumers having supply on specific voltage.

5. Prior period expenses have been duly verified by the Auditor and then classified under this head and the details regarding the same are available at notes of the Audited Annual Accounts. Year wise and item wise detail is a voluminous data and it is not possible to provide the same as of now. 2.13.3. Commission’s view: The Commission has dealt with the issue of other debits and prior period expenses in detail under true up analysis section 3 of this order.

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Part III - Issues/comments related to Investment Plan of FY 2015-16 2.14. Late Filing of Investment Plan 2.14.1. Stakeholders’ Suggestions/Comments: The Commission’s attention is invited to their decision recorded at para 12 of their order dated 12.02.2014 where the Commission came to the conclusion that further processing in terms of public hearing and deciding the plan would not serve any purpose as major part of the financial year was already over and Commission may take a view on the investment made in FY 2013-14 during true up. The same situation has arisen again and the Commission should take a view as was taken in order dated 12.02.2014. 2.14.2. Petitioners’ Response: In response to above, the Discoms submitted that they had filed the MYT Petition in December 2013 for the Control Period FY 2014-15 to FY 2018-19. The Petition was not accepted on the basis that the Regulations for the MYT Control Period were not in place. The Discoms further submitted that the Commission on 24th February 2014 notified the Tariff Regulations. This delay had a cascading effect on the overall timelines and the Discoms filed the Petition for determination of Tariff for FY 2014-15 in June, 2014. The Tariff Order was issued by the Commission on 20th February 2015. After the issuance of Tariff Order, the Discoms undertake review of the Order and consider the impact of various decisions and directives given by the Commission. This entire process requires time. The Commission directed Discom to file the Petitions by 15th July, 2015. The Discoms initiated the process of filing of Petitions in July, 2015. The Discoms made the necessary revisions and amendments in accordance with the directions given by the Commission and Petitions were re-submitted in August, 2015. 2.15. Deposit Work 2.15.1. Stakeholders’ Suggestions/Comments: It was submitted that the JdVVNL in proposed investment plan has included Rs. 20 crore under deposit work. As already decided by the Commission in its order dated 30.11.2012, such expenses do not qualify for inclusion in investment plan.

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JdVVNL has not furnished any Reply. 2.16. Feeder and Sub-Station Improvement Program 2.16.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that Discoms have shown approx. Rs. 469 crore towards feeder

improvement program. On going through the details of such program, it has been observed that all works are relating to repairs and maintenance. Hence, these cannot form part of investment plan.

2. It was also submitted that Discoms have shown approx. Rs. 122 crore towards sub-station improvement program. On going through the details of such program, it has been observed that all works are relating to repairs and maintenance. Hence, these cannot form part of investment plan. 2.16.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that the various works taken up under the head of Feeder Improvement Program are not the day to day normal repair and maintenance works. These works are specifically targeted and are over and above the normal repair and maintenance works. Various works that are targeted under this scheme are replacement of damaged protection boxes for single and three phase meters, replacement of single and three phase obsolete AB cables, augmentation of capacity of single phase transformers in Abadi areas and Dhanies, providing insulated connectors to eliminate direct tapping of AB cables, etc. These works do require a separate capital investment and cannot be put in the same category as that of the normal repair and maintenance works.

2. Similarly, in case of the works to be carried out under Sub-station improvement

program, they cannot be categorized under the normal repair and maintenance works. These works are specially recognized and taken up after due studies and identifying the areas requiring attention. These works have been recognized even by the Government of Rajasthan as essential steps for providing reliable, affordable and quality power for all the consumers.

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2.17. Mukhya Mantri Sabke Liye Vidyut Yojna 2.17.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that Discoms have shown Rs. 240 crore in respect of releasing the pending domestic connections in rural areas and these expenses have been stated under Mukhya Mantri Sabke Liye Vidyut Yojna.

2. With regard to above, it was submitted that there is no provision in the Electricity

Act, 2003 to provide electricity to any kind of consumers without any charges of expenditure incurred. Commission, in their Supply Code Regulations, has prescribed the charges to be recovered from the person requiring supply of electricity (refer Sec. 43 & 46 of EA, 2003). Hence, question of any expenditure under investment program does not arise.

3. However, if any agency/ Government requires or directs the Discoms to carry out such works, they may provide the required amount to the Discoms but in no case such works are required to be done free of charge. Hence, the investment proposed is not admissible. 2.17.2. Petitioners’ Response: Discoms submitted that the scheme was for releasing domestic connections in a group of five in un-electrified dhanies having population less than 100 identified in National Habitation Survey 2003. For the group, the maximum length of LT & HT line permitted is two Km. and the maximum expenditure allowed is Rs. 2.50 lacs. This scheme is stopped now and the pending applications are to be disposed off in DDUGJY. 2.18. RGVVY and R-APDRP 2.18.1. Stakeholders’ Suggestions/Comments:

1. Information of loans being taken against RGGVY and the benefit realised was

sought. 2. With regard to RGVVY and R-APDRP-A&B, it was submitted that these are

Central Government schemes and are to be implemented as per guidelines issued by the Government of India and to be funded by the Government of India. Discoms may please intimate the total amount of the scheme, scheme wise value of works done so far under each scheme, date of completion of

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each scheme, how much work remained to be done and by what time these are to be completed, etc., and what is the cost of works remaining in-complete.

3. It was submitted that in respect of R-APDRP scheme, Discoms have deviated

significantly from approved investment plan during past year. As per clause (E)(2)(c),(3), (4) and (5) of Annexure -1 of the Rajasthan Electricity Regulatory Commission (Investment Approval) Regulations, 2006, no change is to be effected in annual plan over and above 5% of annual investment approval by RERC and investment in various schemes not to exceed 10% of the cost without the revised investment approval. These provisions do not appear to have been followed. 2.18.2. Petitioners’ Response:

1. Regarding RGGVY, 90% of the funds for RGGVY have been provided by Central Government, 20% of the remaining 10% is funded by the State Government and balance (80% of the 10%) has been funded by loan. Large numbers of rural connections have been released under this scheme.

2. They have provided the information as per the prescribed formats of the

Commission. The data required by the Stakeholder is voluminous in nature and the Discoms requested the Stakeholder to seek for such information through a more appropriate platform.

3. The Discoms submitted that the investment proposed for R-APDRP in the original

plan for FY 2014-15 was revised as there were delays in works under R-APDRP. The scope of work to be carried out under this scheme was extended and carried forward to forthcoming years. It is important to note that almost every other State under R-APDRP has witnessed the same scenario. Keeping this in mind, the Government of India has extended the overall timeline of R-APDRP as well. 2.19. Feeder Renovation Programme 2.19.1. Stakeholders’ Suggestions/Comments: Information was sought of investment being made against feeder renovation programme, the quantum of loan and at what rate the loan has been taken against this scheme and also the reduction of losses due to implementation of this scheme.

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1. Regarding feeder renovation programme, Discoms submitted that they have incurred an expenditure of Rs. 4829.83 crore toward FRP, against which government has infused the equity to the tune of 20% and rest is funded by loan. Discoms have raised the loan @12% to 12.5% and from FY 2005-06 to till date losses have been reduced to 12% due to which approx. Rs. 5315 crore have been saved by Discoms.

2. During the Public Hearing, Discoms stated as follows:

a. As far as work under DDUGJY is concerned, its specifications are prepared by the committee and orders for high value items are given through centralised empanelment.

b. As far as the cost benefit analysis or the outcome analysis of various schemes are concerned, Discoms are analysing the important schemes on sample basis and taking up investments only where these are beneficial,

c. The Discoms are separately maintaining the account for the amount being

spent on capital expenditure.

d. Preparation of assets register is important point for the Discoms and with implementation of ERP software, the stock register will be updated.


The Commission has taken note of all the comments of the Stakeholders and Petitioners’ response to them, as summarised above, while passing this order in Section 4 and as well in Section 7 while dealing with the Investment Plan. With regard to deposit work, the Commission finds that such works cannot form a part of investment plan.

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Part IV - General issues/comments related to ARR & Tariff of FY 2015-16 2.20. Incomplete Formats 2.20.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that various formats furnished with the petitions are either incomplete or not fully furnished, such as 2.1, 2.2, 2.3, 2.5, 3.5, 4.1, 6.2, 6.3, 7.2, 7.3 in case of JVVNL, form 2.3, 2.5, 3.4, 3.5, 4.1, 6.3 of AVVNL and form 2.3, 2.4, 2.5, 3.4, 3.5, 4.1, 4.2, 6.1, 6.2, 6.3, 7.2, and 7.3 of JdVVNL.

2. It was submitted that the Discoms have stated that the “Information gathered

and shown to the best possible extent. Some information is missing due to unavailability of specific data at present”. Based on such incomplete data and unreliable data, any determination of ARR & tariff is not desirable. 2.20.2. Petitioners’ Response: In response to above, the Discoms have submitted that the petitions have been filed in accordance with Regulation 11(5) of RERC Tariff Regulations, 2014. All requisite information for determination of ARR and Tariff has been provided with the petitions. Additional information has also been submitted before the Commission on dated 11th March 2016. In view of this, all the completed formats have been submitted. Further, Discoms submitted that the petitions, formats and all additional submission should be considered in totality. 2.20.3. Commission’s view: The Issue of filing of the petition with the incomplete data and information has been dealt by the Commission in the section 1 of this order. 2.21. Review of FY 2014-15 2.21.1. Stakeholders’ Suggestions/Comments: It was submitted that since petitions have been filed in August 2015, the data for FY 2014-15 must be actual instead of estimated. Further, ARR for FY 2014-15 has already been approved by the Commission vide its order dated 20.02.2015. Any second application for review of ARR is not covered under any Regulations. Hence, Discoms may submit true up petition for FY 2014-15 when their accounts are finalized.

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2.21.2. Petitioners’ Response: The Discoms submitted that the Petitions have been filed in accordance with Regulation 11(5) of RERC Tariff Regulations, 2014. All requisite information for determination of ARR and Tariff has been provided with the Petition. 2.21.3. Commission’s view:

The instant petition is for the ARR and Tariff for FY 2015-16. Therefore, the review of FY 2014-15 does not fall within the scope of the current petition. However, the Commission has to look into the figures of FY 14-15 as given in the unaudited account and take a decision on ARR of FY 2015-16. So far as review of FY 2014-15 is concerned, same has to be at the time of true up of FY 2014-15 and not in the present petition.

2.22. Filing of Petition 2.22.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that as per Regulation 6 of RERC Tariff Regulations, 2014, every

licensee has to file the petition latest by 30th Nov. of each year. However, the Discoms have filed the petition in Aug. 2015 for FY 2015-16. Discoms have to state the reasons for non-compliance of the statutory Regulations.

2. It was submitted that due to lapse of time, the Commission in its order dated 12.2.2014 has not approved the Investment Plan for FY 2013-14. The same decision may be taken for ARR for FY 2015-16 as the FY 2015-16 are going to be over.

3. In compliance to APTEL order dated 18.05.2015, the Commission can consider the petitions of Discoms only after audited accounts of FY 2014-15 are enclosed with the petition. Unaudited accounts for 2014-15 have no meaning as the scrutiny of an independent auditor is missing in it.

4. The petition is filed without BOD approval/AGM approval. Further, affidavits from BOD or MD of companies are not enclosed.

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1. In response to above, the Discoms submitted that they had filed the MYT Petition in December 2013 for the Control Period FY 2014-15 to FY 2018-19. The Petition was not accepted on the basis that the regulations for the MYT Control Period were not in place. The Discoms further submitted that the tariff regulations were notified by the Commission on 24th February 2014. This delay had a cascading effect on the overall timelines and the Discoms filed the Petition for determination of Tariff for FY 2014-15 in June 2014. The Tariff Order was issued by the Commission on 20th February 2015. After the issuance of Tariff Order, the Discoms undertook review of the Order and considered the impact of various decisions and directives given by the Commission. This entire process requires time. The Commission directed the Discoms to file the Petition by 15th July 2015. The Discoms initiated the process of filing of Petition in July 2015. The Discoms made the necessary revisions and amendments in accordance with the directions given by the Commission and Petition was re-submitted in August 2015. Looking at all these aspects in a collective manner, the Discoms submitted that objections raised by the Stakeholders are not a true reflection of the facts and the delays were not a non-compliance of the statutory regulations.

2. It is essential that tariff is revised without any further delay. Non revision of tariff

on timely basis led to wide gap between costs and revenue and has been one of the major reasons for the financial distress of the Discoms. The Discoms had to substantially increase short-term borrowings to fund the rising revenue deficit. This increase resulted in sharp increase in cost of borrowings leading to a significant share of interest cost in the total cost. Non revision of tariff on time will lead to further increase in the interest costs which will ultimately burden the consumers in the future. Therefore, Discoms prayed to consider the petitions filed and issue an appropriate order.

3. Audited accounts for FY 2013-14 are enclosed with petitions in due compliance

to Regulation 11(5) of RERC Tariff Regulations, 2014. 2.22.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and reply of Discoms thereto.

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2.23. Hindi Version of Petition 2.23.1. Stakeholders’ Suggestions/Comments:

It was submitted that the petition should also be filed in Hindi version. 2.23.2. Petitioners’ Response: In response to above, the Discoms submitted that the petition for determination of tariff has been filed in both Hindi and English. 2.23.3. Commission’s view:

The Commission has noted that the Discoms have submitted the Hindi version of petitions. However, in future Discom shall ensure that Hindi version of petition is also filed simultaneously. 2.24. UDAY (Ujwal Discom Assurance Yojana) scheme 2.24.1. Stakeholders’ Suggestions/Comments: As per reports, the Rajasthan Government has agreed to participate in UDAY (Ujwal Discom Assurance Yojana) scheme of Govt. of India. Accordingly, State Government will take over 75% of Discoms debt as on 30.9.2015 over 2 years- 50% in FY 2015-16 and balance 25% in FY16-17. Banks/FIs shall waive off any unpaid overdue interest and penal interest on the Discoms’ debt. Therefore, the impact of this scheme must be taken into consideration while determining the tariff. 2.24.2. Petitioners’ Response: In response to above, Discoms have submitted that as per the MoU signed, the outstanding debt of the Discoms as on 30.09.2015 stands at Rs. 80500 crore, out of which 75%, i.e., Rs. 60500 crore would be taken over by the State, as envisaged in the scheme. The scheme also provides for the balance debt of Rs. 20000 crore to be re-priced or issued as State guaranteed Discom bonds at coupon rates around 3% less than the average existing interest rate. The Rajasthan Discoms would have savings of about Rs.3000 crore in annual interest cost through reduction of debt and through reduced interest rates on the balance debt. It is worthwhile to mention that the takeover is expected to be

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done by the end of March 2016 and therefore no benefit is expected in FY 2015-16. 2.24.3. Commission’s view:

Commission will consider the financial impact of UDAY scheme and also the steps taken by GoR and Discoms based on the same while dealing with the ARR petition for FY 16-17 and thereafter. In the meanwhile, for the present, it has taken note of the Scheme, debt taken over and creation of Rajasthan Urja Vikas Nigam for management of power purchase. 2.25. Voltage wise cost of supply 2.25.1. Stakeholders’ Suggestions/Comments: It was submitted that the JVVNL has furnished voltage wise cost of supply. Against the average cost of supply of Rs. 8.43/unit, JVVNL has indicated Rs. 7.04/unit & Rs. 7.20/unit in respect of voltage level of 132 kV & 33 kV respectively. While computing the cost of supply, distribution network cost per unit sale@ Rs. 2.99/unit has been added which is not correct since consumers at 132kV level is not using Discom’s networks. In view of this, cost of supply of industrial consumers would be below Rs. 5/unit. Similarly, for the voltage level at 33kV, the cost of supply would be less than Rs. 5.50/unit considering 3.80% losses in 33kV system. 2.25.2. Petitioners’ Response: In response to above, Discoms have submitted that the voltage wise cost of supply is computed in accordance with methodology determined by Hon’ble APTEL in its Order against Appeal no. 102 of 2010. According to the APTEL order, commercial losses have to be apportioned on each voltage level on sales plus losses basis. 2.25.3. Commission’s view: The Commission has dealt with same under Section 7 of this order.

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2.26. Maintenance of Distribution Lines 2.26.1. Stakeholders’ Suggestions/Comments: It was submitted that Discoms should plan their maintenance schedule and publish it in newspaper 2 days before shut downs so that consumers of the area may be able to plan their business and other activities accordingly. The Discoms should also plan to carry out maintenance in such a way that they carry out complete maintenance feeder wise on holidays and Sundays or when the market or industry keeps holidays. 2.26.2. Petitioners’ Response: In response to above, Discoms have submitted that the suggestions of the Stakeholders will be taken into account. However, in cases requiring unforeseen breakdown maintenance, shutdown will have to be taken up as and when required. During the public hearing, the Chairman Discoms stated that as far as the power cuts are concerned, the Discoms will consider to place the information of the same on web portal of the Discoms. 2.26.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them. As far as the publication of information of shut down by the Discoms is concerned, the Discoms shall ensure the compliance of RERC Standard of Performance Regulations which states that interruption in power supply due to scheduled outages, other than the load shedding, shall be notified by Discoms at least 24 hours in advance for planned shutdown and same day in emergent cases. Notification may be published through media also besides putting on website. 2.27. Defective Meters 2.27.1. Stakeholders’ Suggestions/Comments: It was submitted that meters are purchased with a certain guarantee period. Hence, if these are found defective within the guarantee period, then defective

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meters should be dispatched back to the companies every month immediately instead of keeping them in stores and not taking care of them for a long time. 2.27.2. Petitioners’ Response: In response to above, Discoms have submitted that any instrument/equipment if found defective under guarantee period is got replaced/repaired from the supplier/manufacturer. 2.27.3. Commission’s view:

The Commission desires that replacement of defective meters shall be taken up on war footing level as a major step in reduction of commercial losses. It should be an ideal situation that every installation has a proper meter which is timely read and bills are issued on time.

2.28. Distribution of LED Bulbs 2.28.1. Stakeholders’ Suggestions/Comments:

It was a good step taken by Government and JVVNL to distribute LED bulbs to consumers at a reduced price. The Government may continue this scheme in each and every city, town, village and provide more LED bulbs. But recently, after 3 bulbs, consumers have to pay cash and they are not allowed to take bulbs on monthly instalment. Stakeholder requested to allow consumers to take upto 10 LED bulbs on instalments so that the consumption load is reduced. 2.28.2. Petitioners’ Response:

1. In response to above, Discoms have submitted that LED Bulbs are being

distributed as per the EESL Scheme. Any changes in the scheme will be passed on to the consumers accordingly.

2. During the public hearing, the Chairman Discoms stated that as far as the study for the impact of DELP scheme is concerned, Discoms will approach the EESL for the same.

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The issue of LED bulb has been dealt by the Commission under Section 7 of this order.

2.29. Availability of Bills on Internet/ Website 2.29.1. Stakeholders’ Suggestions/Comments:

It was submitted that earlier the consumers could get the bill copies from Discom website but now only registered consumers are able to take out copy of bills. The Commission may consider issuance of bill from Discoms website on internet without registration too. The updated data of consumers may be collected by Discoms like consumer’s mobile no., email address and inform them of bills issued, payment received on mobile and emails like mobile telephone operators (Pvt.) and BSNL. This will help consumers to know their likely payment schedules in advance and payment position. 2.29.2. Petitioners’ Response: In response to above, Discoms have submitted that registration on the website of the Discom can be done easily and requires no major effort. Once the domestic consumer is registered, on issuance of bill, details of bill amount and due date are sent to the registered mobile number through SMS. Therefore, the consumers can easily know their payment schedule in advance. 2.29.3. Commission’s view:

With regard to registration on the website of Discoms to access the information of consumer electricity bills, the Discoms stated that it’s a simple process to get registered on website of Discoms and Commission feels that the registration process also safeguards the consumer from un-authorized access of his account. 2.30. Notice for Disconnection 2.30.1. Stakeholders’ Suggestions/Comments:

It was submitted that no electric supply should be disconnected by Discoms unless they serve a 15 days notice for payment due, if any. If the consumer does

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not pay within the notice period, then disconnection activities may be taken up. Presently, no notice in writing is given to the consumers and Discom’s persons take action for disconnection immediately after the due date is over. 2.30.2. Petitioners’ Response: In response to above, Discoms have submitted that the process of disconnection on default of payment is being done as per the Terms and Conditions of Supply. 2.30.3. Commission’s view:

While dealing with the issue of disconnection of supply in case of default in payment by consumers, the Discoms must ensure to comply with the Regulation 38 of the RERC Supply Code Regulations and Section 56 of the Electricity Act, 2003. 2.31. Theft of Electricity 2.31.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that direct supply has been taken in the temples situated in

public parks and no proper metering exists in the premises of police stations/police chowkies and police lines, road lights in cities/towns besides residential colonies/quarter situated at substations including offices of the Discoms. No tangible efforts have been made so far except this reply that vigilance checking is being done.

2. It was submitted that Discoms must ensure the proper energy audit and try to detect the theft cases as much as possible.

3. It was also submitted that in case electricity is used by the consumers other than domestic and small non domestic (upto 5 KW) at a load exceeding the sanctioned connected load, assessment is done both for load and energy in proportion to extended load at twice the applicable tariff. Looking to the fact that all energy consumption is metered and paid for, the Commission was requested to reduce the charges and save consumers from harassment.

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1. In response to above, Discoms submitted that over the recent times, it has been stringent and relentless in its vigilance activities. Special vigilance campaign has been launched by the Discoms in recent times considering the theft of electricity. Proper metering is being done on temples situated in public parks, police stations, etc. Instructions have already been given and implemented at most of the places. Due to the constant endeavours of the Discom in the field to curb and control the activities of theft and other misdoings, there has been a major increase in the number of such activities being caught and reported. Also, there is a significant increase in the number of FIR’s lodged.

2. A detailed comparison of vigilance activity is as under:

Month Checking Theft Assessment Realization FIR

(Nos.) (Nos.) (Rs. Lac) (Rs. Lac) (Nos.) JVVNL Apr’14-Oct’14 41351 26959 4231 1261 2614 Apr’15-Oct’15 66889 47421 6855 2918 6631 AVVNL Apr’14-Oct’14 50308 19794 3908.74 1730.48 1440 Apr’15-Oct’15 67991 33650 6453.77 2215.88 2734 JdVVNL Apr’14-Oct’14 17564 5884 2879.73 924.59 1174 Apr’15-Oct’15 48468 16791 5019.59 1745.06 3427

3. From the above it is evident that Discom has substantially increased the vigilance activity. The efforts put in by the Discom in strengthening the vigilance activities has led to a significant increase in revenue realized from vigilance as compared to the previous year (70% y-o-y increase in FY 2015).

4. During the public hearing, the Chairman Discoms submitted as follows:

a. The Distribution transformer metering and energy audit is binding on Discoms because of MOU signed under UDAY scheme.

b. Discoms are also bound by UDAY Scheme for providing AMR metering subject to cost benefit analysis and making efforts to make meter reading free from human intervention.

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1. The issue of theft and energy audit has been dealt by the Commission under

Section 7 of this order.

2. As regards billing of excess load is concerned, the provisions of Electricity Act, 2003 are very clear and need no further elaboration. Discoms shall deal with these cases as provided in Law and ensure that no consumer is harassed. 2.32. Compliance of Guidelines 2.32.1. Stakeholders’ Suggestions/Comments: An affidavit from Discoms is not enclosed that they have followed rules and regulation of various acts and directions issued by the GoI regarding training of staff, safety, approval for energizing lines and transformers from State Electrical Inspector’s office. Further, no mention of compliance of various direction/guidelines of REC, CEA, PGCIL and other authorities is mentioned in the petition. 2.32.2. Petitioners’ Response:

In response to above, Discoms submitted that the petitions are as per provisions of Electricity Act, 2003 and RERC Tariff Regulations, 2014. As far as mention of other compliances of various other directions/guidelines of REC/PGCIL/CEA & other authorities is concerned, it is submitted that they are not required to submit these details along with the petition as per the applicable Regulations. 2.32.3. Commission’s view:

With regard to safety and CEA regulations, the Commission has dealt with the same under Section 7 of this order. 2.33. Consumer Grievance 2.33.1. Stakeholders’ Suggestions/Comments:

There is no mention of special scheme for redressal of consumer grievances in the petition. There is also no mention of use of IT initiatives duly coordinating with

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Digital India programme of Government of India. The concept of chaupals is followed by Discoms, but its actual benefit to consumers is not assessed properly. Steps to involve more Stakeholders in chaupal programme to reduce consumer complaints are also not mentioned. 2.33.2. Petitioners’ Response: In response to above, Discoms submitted that there is a special cell dedicated to redressal of consumer grievances and consumers are availing benefit of the same. The Discoms also submitted that they are committed to use of IT for process improvements. Under R-APDRP scheme, widespread IT implementation is being carried out. The concept of chaupal being followed by the Discom has helped consumers to get their grievances settled on the spot. 2.33.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them. As far as use of Information technology is concerned, it needs no emphasis. The Discoms must promote the use of information technology as that will save the cost and improve their efficiency. Now multiple agencies are available in this field and Discoms shall make use of them in their own interest. 2.34. National Tariff Policy 2.34.1. Stakeholders’ Suggestions/Comments:

1. What are the difficulties in compliance on para 8.2 (Framework for revenue requirements and costs) and 8.3 (Tariff design: Linkage of tariffs to cost of service) of National Tariff Policy while filing the tariff petition?

2. A uniform tariff should not be determined for all the 3 Discoms due to the

varying geographical conditions, ARR, losses, etc. 2.34.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that the petition is filed in compliance to National Tariff Policy, Electricity Act, 2003 and RERC Tariff Regulations.

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2. The tariff for all the 3 Discoms has been proposed at the same level to maintain

uniformity among the consumers across the State. 2.34.3. Commission’s view:

The Commission has computed the cross subsidy under the Section 6 of this order. 2.35. Fuel surcharge 2.35.1. Stakeholders’ Suggestions/Comments:

Stakeholder stated that the information of fuel surcharge is not placed in public domain and sometimes the industrial consumers come to know the amount at a very late stage, therefore, the impact of same could not be loaded on the product costing and they have to bear the loss. 2.35.2. Commission’s view:

Discoms should place details of calculations of fuel surcharge on their website before raising the claims so that the consumers are informed of it. Further, the calculation of fuel surcharge and its realization should be done in every quarter in order to see that the licensees recover their fuel costs regularly to meet their objective of recovering fuel surcharge as and when incurred and as per APTEL order in OP No. 1 of 2011. If it is not levied in any quarter, the same should be recovered only through ARR at the time of true up and not by way of supplementary claims in any other quarter.

2.36. Prepaid metering 2.36.1. Stakeholders’ Suggestions/Comments:

1. Some industrial consumers requested that they should also be allowed to use

prepaid meters and they are also ready to purchase their own meters for the purpose.

2. It was submitted that BSNL provides the emergent nature of services, viz., Land line telephone, cellular mobiles services, broad band services, toll free numbers,

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call centres and other social obligations in the interest of public, therefore pre-paid meters should not be compulsory for BSNL. 2.36.2. Petitioners’ Response:

In response to above, JVVNL submitted that the Commission in its order dated 20th February 2015 felt the need to promote pre-paid meters. Also, in order to increase revenue collections, the JVVNL has launched pre-paid metering program. To begin with, this has been launched for all Government Departments which was also in line with 2012 FRP of GoI. 2.36.3. Commission’s view:

Commission observes that it is for the Discoms to decide the phasing of prepaid metering. Discoms may also consider installing prepaid meter for temporary connections as per RERC (Metering) Regulation, 2007, as these connections are for a fixed time period. This will also ensure prevention of unauthorised extension of consumption, if any.

2.37. Open Access 2.37.1. Stakeholders’ Suggestions/Comments:

Some industrial Stakeholders requested that the open access should also be allowed to consumer having 100 KW connections. 2.37.2. Commission’s view:

As per RERC (Terms and Conditions for Open Access) Regulations, 2016, the Open Access is admissible to consumers with contract demand of one MVA and above. The present petitions pertain to ARR and Tariff, therefore the Commission has not dealt with the prayer of allowing open access below 1 MVA.

2.38. Monthly Billing 2.38.1. Stakeholders’ Suggestions/Comments:

Some of the Stakeholders stated that consumers must be billed on monthly basis instead of bi-monthly billing, as the consumer are not sure whether they are getting the benefit of lower tariff under certain slabs in each month.

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2.38.2. Commission’s view: The Discoms may examine shifting to monthly billing cycle in case of domestic consumers in a phased manner starting with consumers having consumption of more than 500 units per month. This step is expected to help companies to recover their charges without loss of time and will also reduce the burden of consumers in paying the bills of two month in one go. Further, this may also avoid complaints regarding slab wise charges.

2.39. Staffing pattern of Discoms 2.39.1. Stakeholders’ suggestions/comments:

Recruitment of new staff and officers are not in same proportion of increase in consumers and connected load. Stakeholders strongly stated that due to acute shortage of staff and officers, particularly Lineman and other technical field staff, the maintenance works suffer and restoration of supply gets considerably delayed. Proper training is also not being imparted to the staff. One of the Discom’s officers also raised the issue that the existing staffs are over burdened and they are not able to perform their duty properly and meet the expectation of the consumers. 2.39.2. Commission’s view:

The Discoms should look into the issue of shortage of manpower at each level as it has a direct impact on the quality of consumer service provided by them. The Discoms may review the existing staffing pattern vis a vis growth in number of consumers, load, lines and transformers as well as the requirement of various Regulations of RERC and CEA. The Discoms need to impart the necessary training to its employees as required under law and also conduct refresher courses for employees at various levels. The Commission vide its order dated 04.08.2016 in the matter of RSEB Engineer Associations Vs. Discoms has already directed Discoms to consider the issue of adequacy of work force and take action as deemed necessary in a time bound manner. Discoms may take necessary action accordingly.

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PART – V: ARR Related Issues/Comments 2.40. Sales Forecast 2.40.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the CAGR of 7 years has been taken for some categories and CAGR of 3 years for others without indicating reasons. It appears that different basis for CAGR has been considered to project higher sales.

2. It was submitted that the large industrial power sales have shown decreasing trend for FY 12-13 and FY 13-14 and increasing trend thereafter. Clarify the same.

3. It was submitted that sales to electric traction has steep fall from 404.11 million

units in FY 13-14 to 145.86 million units in FY 14-15 (vide Table 20). There appears to be no reason for such steep fall as there is no reduction in activity of Railways. 2.40.2. Petitioners’ Response:

1. The Discoms submitted that considering a common CAGR for all categories will not be appropriate. For estimating the sales for the ensuing year, it is important to consider ongoing changes in each category. Therefore, in some categories a 7-year CAGR will give a better representation while in other categories due to certain changes in pattern, a 3-year CAGR will be more appropriate.

2. Discom submitted that the decreasing trend of sales in large industrial category is due to shift of consumers into open access. Discom further submitted that after implementation of new billing software in FY 2014-15, part of Railway category was merged into large industries for MIS creation purpose and therefore the sales of Railways have shown a steep fall while the sales of large industries have shown a rise. 2.40.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them and dealt with this issue under Section 5 of this Order.

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2.41. Power Purchase 2.41.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that impact of cess, electricity duty, etc. has not been considered in per unit power purchase cost, which needs to be considered as per last bills from generating companies. Low average energy cost may lead to high fuel surcharge under Regulation 88 of RERC Tariff Regulations, 2014.

2. One of the Stakeholders has sought the copy of power purchase agreements entered into for purchase of power by Discoms.

3. It was submitted that the rate of charges for both fixed and energy/variable charges may be intimated in respect of each source.

4. It was submitted that availability of power from various stations of RVUN as taken by the Discoms is on lower side as compared to that petitioned by RVUN and approved by the Commission in their order dated 07.09.2015. 2.41.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that for computing the cost of power purchase, the methodology as adopted in the past has been considered. Any variation will be taken into account during the time of True-up.

2. The distribution companies have long term agreements with multiple sources. These sources have been used to project the power purchase for FY 2015-16. The PPAs signed by the Discoms are also reviewed by the Commission.

3. Capacity charges and variable charges have been shown separately in Form No. 3.1.

4. The availability of power from various sources has been projected considering the actual power availability in the past.

5. During the public hearing, the Chairman Discoms submitted as follows:

a. Discoms are putting their best effort for reduction in power purchase cost.

The major chunk of power comes from long term sources for which the

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tariff is decided by the appropriate Commission. Possibility of reduction is only in short term sources.

b. Discoms have effected better grid management and control regarding under and over drawal.

c. PFC has made an e-platform for purchase of bilateral and short term power purchase and Discoms are making use of that.


The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them and dealt with this issue under Section 5 of this Order. 2.42. Transmission Charges and Losses 2.42.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the Commission has determined the provisional tariff of RVPN vide its order dated 14.08.2015 for FY 2015-16. However, Discoms have not given the effect of the same in their petition.

2. It was submitted that instead of Discoms’ claim of 4.20 % transmission losses for

FY 2015-16, the transmission losses should be allowed as per Commission’s order dated 14.08.2015. 2.42.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that it is not possible to revise the petition submitted with every new order that is issued for other generating/transmission licensee. Revision of petition will take time which will lead to further delays.

2. Regarding transmission losses, the Discoms submitted that the Commission may take an appropriate view. 2.42.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them and dealt with this issue under Section 5 of this Order.

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2.43. Distribution Losses 2.43.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that the three Discoms have projected higher distribution losses for FY 2014-15 and FY 2015-16 as compared to trajectory specified by RERC in its order dated 20.02.2015.The distribution losses should be allowed as per the trajectory specified in RERC order dated 20.02.2015.

2. To reduce energy losses, a scheme was approved by the Government of India for existing agriculture pump sets to be replaced by star rated pumps. This scheme’s progress & energy saved by implementing the scheme is not reported in the petition.

3. Stakeholders have also raised the issue of higher commercial losses and stated

that responsibility of field officers should be fixed for higher commercial losses. 2.43.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that the distribution loss for FY 2014-15 has been submitted according to the provisional accounts. Accordingly, reduction on the same has been considered for FY 2015-16 and for computation of energy requirement. Discoms also submitted to consider the losses as prayed considering the adverse financial position of the Discoms.

2. In response to above, the Discoms submitted that the scheme for replacing the agriculture pump sets with star rated pump sets is under finalization. It will be implemented in the manner specified in the final scheme.

3. Discoms submitted that all efforts are being taken to reduce distribution losses

along with regular vigilance checking. 2.43.3. Commission’s view:

1. The Commission has considered the Distribution losses as per the trajectory

prescribed for FY 2015-16 vide its order dated 20.02.2015.

2. The Commission observes that commercial losses is the one area which needs to be focused on as commercial losses can be reduced without making much of

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an investment and can be reduced immediately whereas reduction of technical losses may require investments in infrastructure and time to develop them. As such, Discoms should need to work out technical and commercial losses separately, identify the areas with high commercial losses and focus on its reduction and report the same to the Commission. 2.44. Operation and Maintenance Expenses 2.44.1. Stakeholders’ Suggestions/Comments: It was submitted that Commission may allow these expenses separately as per norms prescribed in the Regulations on the basis of correct figure of sales. 2.44.2. Petitioners’ Response: In response to above, the Discoms submitted that breakup of O&M expenses into employee expense, A&G expense, R&M expense, as per the provisions of RERC Tariff Regulations, 2014 has been provided in the petition. 2.44.3. Commission’s view: The Commission has computed the O&M expenses for FY 2015-16, as per the norms prescribed in the RERC Tariff Regualtion2014. 2.45. Terminal Benefit 2.45.1. Stakeholders’ Suggestions/Comments

1. It was submitted that the Discoms have not submitted actuarial valuation report and therefore the correctness of claim of terminal benefit cannot be judged.

2. It was submitted that the terminal benefits are part of employees cost and as such the Discoms should part with the required amount from their employee’s expenses and no additional funds are required to be allowed. 2.45.2. Petitioners’ Response:

1. In response to above, Discoms submitted that the actuarial valuation report has been submitted along with these replies.

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2. The terminal benefits should be allowed in accordance with the previous orders of the Commission.


The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them. 2.46. Interest on Working Capital 2.46.1. Stakeholders’ Suggestions/Comments

1. It was submitted that while computing the interest on working capital, terminal

benefit should not be part of O&M.

2. It was submitted that Interest on working capital must be allowed on normative basis only.

3. It was submitted that no justification has been provided by the Discoms on the extremely high interest on the working capital. 2.46.2. Petitioners’ Response: In response to above, Discoms submitted that the Working Capital requirement has been computed in line with Regulation 27(1) (3) of RERC Tariff Regulations, 2014. 2.46.3. Commission’s view:

The Commission has computed the interest on working capital for FY 2015-16, as per the norms prescribed in the RERC Tariff Regulation 2014. 2.47. Depreciation 2.47.1. Stakeholders’ Suggestions/Comments

1. It was submitted that the Discoms have no proper and regular assets register.

Depreciation is being claimed by them on an arbitrary basis.

2. It was submitted that Depreciation needs to be reworked out on normative basis and thus there is sufficient reduction in the ARR as against that which has been projected.

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1. In response to above, the Discoms submitted that the work relating to preparation of Fixed Assets Register and other allied works for the year 2000-01 to 2012-13 has been outsourced to M/s Ankit Maheshwari & Associates, CA’s, Jaipur which is under progress. The same has been mentioned in the Annual Audited Accounts also.

2. Various components of ARR are projected on normative basis as per the Tariff

Regulations, 2014. 2.47.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them and dealt with this issue under Section 5 and 7 of this Order. 2.48. Interest and Finance Charges 2.48.1. Stakeholders’ Suggestions/Comments

1. It was submitted that no interest should be allowed on short-term loan other than on Working capital loan.

2. Similarly, no interest should be allowed on the short-term loan obtained for meeting the revenue deficit.

3. Interest on loan being utilized for works in progress is also not to be allowed in ARR. Interest on loan may be allowed on the amount admitted by the Commission as invested for admitted capital works only.

4. The three Discoms have proposed interest on loan of Rs. 9820 crore. It seems they have also included the interest charges disallowed by the Commission.

5. The expenditure on interest liability is approx. 22% of the total ARR, which is excessive and needs to be checked up and brought under the control of efficient financial management.

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6. Discoms have not indicated the interest earned on security deposits of consumers. This may now be intimated. 2.48.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that it is not the poor financial management but non-revision of tariff on timely basis which led to a wide gap between costs and revenue and has been one of the major reasons for the financial distress of the Discoms. As there was no increase in the tariff rates from FY 2005-06 to FY 2010-11, the Discoms had to substantially increase the short-term borrowings to fund the rising revenue deficit. This increase resulted in sharp increase in cost of borrowings leading to a significant share of interest cost in total cost.

2. As per the RERC Tariff Regulations, 2014, the amount of security deposit is taken into account while computing the working capital requirement. This implies that the Discoms use the security deposit to meet its working capital and therefore the question of interest earned on security deposits does not arise. Consumer security deposit is in the nature of capital receipt and is being utilized for capital expenditure. 2.48.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response to them and dealt with this issue under Section 5 of this Order. 2.49. Insurance Expenses 2.49.1. Stakeholders’ Suggestions/Comments

It was submitted that the Regulation 25 of Tariff Regulations, 2014 clearly states that insurance expenses are based on actual basis. The Discoms may supply the copies of relevant documents to substantiate their claim.

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2.49.2. Petitioners’ Response: In response to above, the Discoms submitted that insurance expense has been computed as per the Regulations taking 0.2% of the Net Fixed Assets for FY 2015-16. 2.49.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response. 2.50. Sale of Power at Lower Rate 2.50.1. Stakeholders’ Suggestions/Comments: It was submitted that the proposal of Discoms to sell the surplus power at Rs. 2.21 per unit is unacceptable as the Discoms are purchasing the power at an average tariff of 3.80 per unit. The Discoms may follow the direction given in the order dated 20.02.2015 of selling the power at Rs. 4 per unit. 2.50.2. Petitioners’ Response: In response to above, the Discoms submitted that purchase of energy is a dynamic situation and short-term power purchase cannot be relied upon. To ensure energy security in the State, the Discoms had to bank upon long term power purchase sources. However, it is worthwhile to mention that due diligence is done and all steps are undertaken to take maximum benefit of power available at cheaper rates. 2.50.3. Commission’s view: The Commission has dealt with the issue of rate of sale of surplus power, under section 5 of this Order. 2.51. Revenue Deficit 2.51.1. Stakeholders’ Suggestions/Comments: It was submitted that the Discoms have considered carrying cost of revenue deficit of FY 2014-15 in arriving at annual revenue requirement for FY 2015-16.

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Revenue deficit must have been the part of unfunded liability and as such this is not to be considered again. 2.51.2. Petitioners’ Response: In response to above, the Discoms submitted that carrying cost has been considered as per the methodology adopted by the Commission in its previous tariff order. 2.51.3. Commission’s view: The Commission has considered the interest on unfunded liability only to the extent of approved cumulative revenue deficit.

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PART – VI: Tariff Related issues/comments 2.52. Fixed Charges, Other Charges and Cess 2.52.1. Stakeholders’ Suggestions/Comments

It was submitted that it is not correct to recover the fixed charges, other charges and urban cess in electricity bill along with energy charges. 2.52.2. Petitioners’ Response: In response to above, the Discoms submitted that the fixed charges are recovered towards facility made available to consumers and operation & maintenance of its infrastructure and billing system. Other charges are recovered toward fuel surcharge. On the direction of State Government, urban cess is being recovered through electricity bill and Discoms are depositing the same with the State Government. 2.52.3. Commission’s view: The Commission has taken note of the comments of the Stakeholders and Petitioners’ response. 2.53. Increase in Tariff 2.53.1. Stakeholders’ Suggestions/Comments:

1. It was submitted that instead of increase in tariff, the distribution losses should be

reduced.

2. It was submitted that tariff proposal does not indicate underlying principles of tariff enhancement. It proposes almost same enhancement in fixed and energy charges. It is a fact that fixed charges of tariff are much less than fixed charges of generation, transmission and distribution and this difference is recovered through energy charges. Short-term open access is decided by the consumer on the economics based on energy charges of tariff and rate at which electrical energy is available in the power exchange. With hike in energy charges, open access will become more lucrative and there may be more migration to open access. Unless energy charges are reduced, either by increasing fixed charges only or by incentives, trend of migration to open access or solar energy generation, cannot be reversed.

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3. It was submitted that tariff in Rajasthan is already very high as compared to

other States. It is requested not to increase the tariff for FY 2015-16.

4. It was submitted that in proposed tariff, energy charges for number of categories are above Rs. 6.00 per kWh. Large solar PV power plants tariff has reached to Rs. 5.00 per kWh. For smaller installations, it may be high but less than Rs. 6.00 per kWh. High energy charges will prompt number of consumers to have solar PV installations (grid connected or otherwise). This aspect has not been considered in tariff proposals.


1. In response to above, Discoms have submitted that the Tariff has been proposed in line with applicable legislative policy and regulatory framework. Hike in fixed charges and energy charges is necessary considering the inflationary increase in cost of material as well as manpower and to bridge the revenue gap from past period and estimated revenue gap for FY 2015-16.

2. The per unit energy charge from smaller installations of Solar PV will be much

higher than that projected by the Stakeholders. The Discoms submitted that it is committed to promote renewable sources of energy and the Commission has notified Net Metering Regulations to give an additional impetus to solar energy sources. All this has been considered while making the petition.

2.53.3. Commission’s view: The Commission has taken note of the comments of the Stakeholders and Petitioners’ response and dealt with the issue under section 6 of this Order. 2.54. Increase the Rate of Rebate for Prompt Payment 2.54.1. Stakeholders’ Suggestions/Comments

1. It was submitted that the rate for prompt payment should be increased from 0.15% to 0.25%.

2. Some of the Stakeholders also stated that the benefit of the prompt payment is not available to them.

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2.54.2. Petitioners’ Response: In response to above, the Discoms submitted that as far as suggestion for increasing the rate for prompt payment from 0.15% to 0.25% is concerned, it is submitted that it is not tenable. At this rate, the monthly rate of interest comes out to be 1% per month, which is very high, which is not even given on bank FDs. 2.54.3. Commission’s view:

The Commission in the last year tariff order dated 20.02.2015 had allowed an incentive of 0.15% on prompt payment where the payment is received before seven (7) working days with the direction that Discoms should ensure timely delivery of bills so that maximum number of consumers may avail benefit of the same. The Discoms shall give effect to incentive provided without fail.

2.55. Restructuring of Tariff Rates for Billing Purposes 2.55.1. Stakeholders’ Suggestions/Comments It was submitted that all the slabs should be abolished and only one slab should be applicable. This will ease the billing system and consumers will understand the clear charge billed to them. 2.55.2. Petitioners’ Response: The Discoms submitted that the slabs and tariff structure have been decided after proper scrutiny by the Commission. The Discoms have not proposed any change in the slabs in its proposal for Determination of Tariff for FY 2015-16. However, if in future, any change in slab appears to be beneficial, it will be taken up by the Discoms after due diligence. 2.55.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response.

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2.56. Average Cost of Supply 2.56.1. Stakeholders’ Suggestions/Comments

It was submitted that the power purchase and transmission charges account for 70% of total per unit cost in case of normal distribution business. The Discoms cost of power purchase and transmission charges are Rs. 4.45/unit. Therefore, average cost of supply should be brought down to Rs. 6.50 per unit (4.45/70%) instead of Rs. 8.33 per unit proposed by Discom. 2.56.2. Petitioners’ Response:

In response to above, the Discoms submitted that the determination of tariff is done as per the legislative policy, tariff regime and in accordance with Tariff Regulations, 2014. Suggestion proposed by the Stakeholders has missed the other components of tariff structuring like operation and maintenance cost, interest and financing charge, return on equity and capital expenditure made in the direction to ensure the reliable and rational supply of power to all consumers. When such factors are taken into consideration, the actual cost of supply increases significantly as compared to the actual revenue realized from sale of energy. 2.56.3. Commission’s view:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response. 2.57. Voltage Rebate 2.57.1. Stakeholders’ Suggestions/Comments It was submitted that JVVNL should extend the benefit of suitable voltage rebate to the BSNL exchanges having HT connection and contracted demand below 50 KVA as applicable. 2.57.2. Petitioners’ Response:

In response to above, JVVNL submitted that voltage rebate is being provided to consumers as per the Terms and Conditions of Supply. JVVNL also submitted that voltage rebate is provided based on contracted demand and not actual demand. JVVNL has not proposed any change in the same.

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2.57.3. Commission’s View:

The Commission has taken note of the comments of the Stakeholders and Petitioners’ response. Tariff Proposal 2.58. Domestic Category 2.58.1. Stakeholders’ Suggestions/Comments

1. It was submitted that in the case of JVVNL, as per its true up petition of FY 2013-

14 (form 2.1), total no. of domestic consumers (other than H.T. domestic) is 3121333 whereas in FY 15-16 the number of such consumers has been shown as 3092114, i.e., on reduced side. Presentation of reduction in number of consumer affects the revenue on lower side. Discom is to give proper justification for such reduction.

2. For the domestic consumers with consumption above 300 units/ month, tariff has been proposed to be increased from Rs. 6.00/unit to Rs.6.70 /unit and for consumption above 500 units, it is proposed to increase from Rs. 6.40/unit to Rs. 7.15/unit. It is suggested that for these categories, tariff should not be increased and kept at the existing level only, i.e., Rs. 6.00/unit and Rs. 6.40/unit respectively. Otherwise, the domestic consumers will go for roof top solar power in a big way in order to restrict their consumption up to 300 unit per month for which the Government of India is providing 30% subsidy.

3. Tariff of domestic category is already very high. This should not be increased again. 2.58.2. Petitioners’ Response:

1. In response to above, the Discom submitted that the number of consumers shown in Form No. 2.1 for FY 2013-14 includes PDC consumers. The regular number of consumers for FY 2013-14 for domestic category is 26,54,232. Whereas, for FY 2015-16 the number of regular consumers is projected at 30,92,114. Therefore, the number of consumers for domestic category shows an increase.

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2. ARR and Tariff Proposal for FY 2015-16 are made in accordance with the tariff

structure and legislative policies. It is pertinent to mention here that there had been no tariff hike from FY 2004-05 to FY 2010-11. Due to non-increase in tariff over the past few years, the unfunded gap has piled up and has eventually lead to a financial duress on the Discoms. Considering the awful financial situation, proposed tariff hike should be allowed to the Discoms. 2.59. Non Domestic 2.59.1. Stakeholders’ Suggestions/Comments

1. It was submitted that the services provided by the educational institutes are

essential as it prepares the youth for technical career and it is important that the cost of enterprise remains as economical as possible. Prior to 2010, the Discoms were billing power consumption of educational institutes under Mixed Load Tariff but suddenly placed these under the highest tariff category of Non Domestic thereafter. This change has affected the education economics adversely. The activities in educational institutions are primarily social and not commercial in nature. All the educational societies of the Stakeholders are Non-Profit making and do not work on commercial basis. As such charging commercial tariff from social and socially committed and honest consumers is harsh and against the Government policies of social commitment. The Stakeholders urged the Commission to consider the objection and provide relief from the same.

2. It was submitted that BSNL is a purely state owned telecommunication company with 100% Govt. Stake. It should be covered under Bulk supply for mixed load for HT and LT connections as applicable to educational institutes run by government or agencies of the government, railways, defence establishments, aerodromes, etc. 2.59.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that no change has been

proposed to categorization of Hostels under the tariff proposal this year. The change in category in the previous order was approved by the Hon’ble Commission after due deliberation and discussions and therefore the Discoms have no additional submission on the same.

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2. The Discoms submitted that the tariff is being charged to consumers as per the Tariff Order dated 20th February 2015 notified by Hon’ble Commission. The Discoms have not proposed any change in categorization of consumers in the Petition under review. 2.60. Agriculture 2.60.1. Stakeholders’ Suggestions/Comments

1. It was submitted that the proposal of increase in tariff of agriculture category should not be accepted.

2. It was submitted that the distance of distribution lines of the industrial and domestic consumer is short and whereas it is long in case of agriculture consumers. Therefore, some solution should be sought out so that the agriculture distribution losses can be reduced.

3. It was submitted that in the agriculture category, both metered and flat rate consumers contribute 40% of the total sales, whereas the revenue realization from this category is just 13% to 14% of total revenue realization. Therefore, the consumers of other categories should not be burdened with such gap. 2.60.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that to supply the power to consumers, Discoms have to purchase the power and any increase in power purchase cost also leads to increase in tariff. However, it is pertinent to mention here that the since 2001, there is no increase in tariff of agriculture category as the Government bears the burden of any increase in tariff of agriculture category.

2. Separate transformers are installed on release of agriculture connection and

continuous efforts are being made to reduce the agriculture category losses. 3. During FY 2014-15, the agriculture category contributed 41% of total sales and

33% of total revenue has been realized from this category.

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2.61. Conversion of Agriculture Flat Rate Consumers to Metered Consumers 2.61.1. Stakeholders’ Suggestions/Comments

It was submitted that the Discoms have failed to convert all agriculture flat rate consumers to agriculture metered consumers which is a clear case of disobedience of orders of the Commission even after lapse of quite a long period. 2.61.2. Petitioners’ Response: In response to above, the Discoms submitted that continuous efforts are being made towards conversion of flat rate agricultural consumers to metered consumers. It is worthwhile to mention that conversion of consumers from flat rate to metered category is a long process and also faces public resistance. Even then, it can be seen that over the years the number of flat rate consumers have decreased and have been converted to metered consumers. 2.62. Industry 2.62.1. Stakeholders’ Suggestions/Comments

1. Fixed charges are again increased by Rs. 5 to 15 rupees per HP or KVA. The tariff is already very high in this head and Discoms are adding more and more with every increase in tariff.

2. It was submitted that the average realization from industrial consumers, specially the large industry, has been indicated as Rs. 7.78/unit at existing tariff. The average revenue realization would be Rs. 8.69/unit at the proposed tariff. Such increase in the tariff is neither justified nor required. With the increase in the tariff beyond the existing tariff, consumers will move towards captive generation, open access & solar power. 2.62.2. Petitioners’ Response:

1. In response to above, the Discoms submitted that a hike of approximately 10% is

essential to bridge the revenue gap and ensure improvement in quality and reliability of power supply as business of supply of electricity is just like any other business which needs sufficient flow of funds for undertaking its operations. Over the years there has been an increase in the cost of generation and transmission

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as well as inflationary increases which have led to increase in per unit cost of power supplied. Apart from this other essential expenses like cost associated with the purchase of equipment, setting up of reliable infrastructure including lines and substations is also required to be undertaken in order to cater to the growth in demand and improving the quality of supply of power to the consumers. Thus, the nominal increase in the tariff rates proposed by the Discoms is necessary.

2. ARR and Tariff Proposal for FY 2015-16 are made in accordance with the tariff structure and legislative policies. However, under various provisions of Act and existing regulatory framework, JVVNL is already allowing the consumers to avail the benefits of sourcing energy through the route of Captive plant, Open Access and Roof Top Solar. JVVNL has put its best efforts to maintain the reliable network for supply of uninterrupted and quality power to the consumers. This has an embedded cost and shall be allowed to be recovered from the tariff. If proposed tariff would not be allowed to JVVNL, this will have a cascading effect and ultimately will impact the sustainability and financial viability of the Discom.

2.63. Railways and JMRC 2.63.1. Stakeholders’ Suggestions/Comments

1. It was submitted that in respect of Billing of Jaipur Metro according to the integrated maximum demand, the Discom has stated that it will be required to keep additional spare capacity for transformers and equipments and as such this facility may be extended to Metro when it bears the transformer cost or by having its own transformer installed or by paying the rental charges for the transformer installed by the Discom. Integration of maximum demand as per MRI records of meter reading at various substations feeding to Jaipur Metro is to be carried out through software and for that no additional transformer or equipment is required. JVVNL may clarify their stand.

2. As per para (2) of general conditions of applications of tariffs, tariffs are

applicable to only one point of supply and at a single voltage. Supply at other point or at other voltage shall be separately billed. However, in respect of railway traction connections, the maximum demands recorded on various stations on a route are being integrated and used to compute billing demand, which is against the above referred provisions.

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Even the Commission in its tariff order dated 20.2.2015 at para 2.69.3.3 has given directions to Discoms as below:- “As such the Commission again directs to examine the technical implication of allowing such facilities to railways and furnish the reasons why such facility shall not be extended to JMRC.” Discoms have not submitted any such implication in the petition.

3. It is also understood that JVVNL is integrating the demands of Baran and Chhabra station with the demand of stations at Ramganj Mandi, Lakheri, Sawai Madhopur, Gangapur, Bharatpur, etc., specifically when these two stations, namely Baran and Chhabra, are not on the route of the other stations. Discom is to give reasons for deviation and also state as under whose directions/ orders such deviation has been done. Copy of orders imparted by the authority for such practice may kindly be supplied.

4. Discrimination is being made in respect of causing maximum demand over and above the contract demand between large industrial consumers and other H.T consumers. In the case of large industrial consumers, such limit is 10% whereas in case of other H.T consumers such limit is only 5% of their contract demand. The reason for such discriminations requires to be clarified by the Discoms.

5. Though the Discom has suggested for not allowing 10% rebate, but it is not clear as to why sub meters may not be installed for metering the consumption of non-traction load.

6. JMRC submitted that once it was already decided during meeting of 13.04.2015 to propose a single tariff in line with other metro services in the country, there is no question of such tariff without 10% rebate on HT tariff applicable to Railways traction of Indian Railways as it is neither in the spirit of RERC order dated 06.06.2013 & 20.02.2015 nor is in line with the tariff applicable to other metro services in the country.

7. JMRC also submitted that it has already paid the demand for 10 MVA load at each of its two sub-station, i.e., for total 20 MVA at the time of release of connection to JVVNL as well as RVPNL. JVVNL should extend maximum integrated demand facility to JMRC without any delay till JMRC is within the

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integrated demand of 20 MVA or 10 MVA for each of its sub-stations. JMRC agree to pay the augmentation charges at a stage where JMRC requires to exceed the 20 MVA total demand or 10 MVA demand of each sub-station.

8. JMRC submitted that the load pattern of metro technology is having leading power factor and JVVNL was imposing heavy power factor in electricity bills in absence of any such provision (for allowing blocking of leading power factor load of JMRC) in tariff and these charges were being paid by JMRC under protest. 2.63.2. Petitioners’ Response:

1. The Discom submitted that the billing of Jaipur Metro according to integrated

maximum demand is not only a matter of providing a single bill but also means providing the facility to Jaipur Metro to be able to use capacity up to the integrated maximum demand level at any connection point at any point of time. This also means that at each connection point, facility has to be provided to ensure supply equivalent to sum of demand of all connections. For this purpose, additional spare capacity for transformers and equipment will be required.

2. Discom submitted that no change is required in case of Railways who are

availing integrated maximum demand. For Railways, at each point, the demand can rise when at a single juncture multiple trains are passing by. To cater to such fluctuating and intermittent demand, integrated demand has been provided. However, it is worthwhile to note that such facility is available only for traction demand and not for non-traction demand.

3. In case of JMRC, as communicated by JMRC officials and verified by JVVNL officials, segregation of traction and non-traction load is not feasible. Therefore, the facility of integrated maximum demand cannot be offered to JMRC.

4. The Discom submitted that the terms and conditions of tariff are decided based on various parameters in which special conditions of categories are also kept in mind. Such variations in terms and conditions are not to discriminate but to cater in an appropriate way to that category. For example, integrated maximum demand is provided only to Railways looking at the peculiar nature of service and its requirement. Similarly, 10% tolerance over and above the contracted demand is provided only to large industrial consumers as in this category, there

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are more chances of crossing the contract demand because of heavy machinery and other related processes. Such variations do not occur for other HT consumers like in Non-Domestic where the load is constant at all times.

5. Therefore, different parameters are set for different categories based on the consumption pattern and behaviour of the consumers pertaining to that category and cannot be generalized to all categories.

6. A meeting was held on 13th April 2015 in compliance of directives of RERC given in Retail Tariff order dated 20th February 2015 regarding examination of issue of separate metering and billing of traction/non-traction load of Jaipur Metro. In the meeting, it was intimated by the Jaipur Metro representatives/officers that it is not feasible to segregate traction and non-traction load by Jaipur Metro for separate metering and billing purposes. The supply is being given at a single point at 132 kV after which the entire network is being maintained by JMRC. Therefore, the point of sub-metering does not arise.

7. JMRC was provisionally being charged under NDS category which has a higher tariff as compared to HT Industry Tariff. The Commission had proposed a rebate of 10% on traction load only. Even in case of railways the rebate was provided only on the traction load. In case of Jaipur Metro, as discussed in the meeting of JMRC officials and JVVNL officials, such segregation cannot be done. Also, as communicated by JMRC, over 70% of their load is Non-Traction load; therefore such rebate should not be applicable.

8. JVVNL submitted that providing this facility means that the Discom has to keep additional spare capacity which would be solely blocked for Jaipur Metro. This leads to extra transformer and equipment cost. Additionally, the backup system also has to be maintained to cater to such needs. Therefore, the JVVNL has proposed to the Commission that this facility may be extended to Metro when it bears the transformer cost and by having its own transformer installed or by paying the rental charges for the transformer installed by the JVVNL.

9. JVVNL submitted that that power factor surcharge is being charged as per the Tariff Order notified by the Commission. 2.64. Commission’s view on above comments/suggestion

The Commission, while passing this order has taken note of all the comments of the Stakeholders and Petitioners’ response to them summarised as above. The issue of Tariff has been dealt by the Commission under Section 6 of this Order.

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Section -3: Analysis of True Up of Discoms for FY 2013-14

3.1. Discoms have submitted petitions for truing up of ARR on the basis of audited accounts as follows: (i) JdVVNL - FY 2013-14 (ii) JVVNL - FY 2013-14 (iii) AVVNL - FY 2013-14

Analysis of True Up of ARR for FY 2013-14 – JdVVNL

Sale of Energy

3.2. The Discom has indicated total sale of 14586.58 MU including 1,685.28 MU sales to flat rate category. It has been observed that at the beginning of the year, connected load of flat rate consumers was 685203 kW and after taking into account conversion of flat rate consumers to metered category, the closing connected load became 686027 kW. It has been observed that there is increase in connected load per consumer due to decreasing ground water level. The Commission has worked out the sales on the basis of average connected load of 685615 kW and by considering the normative specific consumption, i.e., 1945 kWh/kW/year; the sales to flat rate category shall be 1333.52 MU. Based on the revised sales to flat rate consumers, the total allowed sale of energy is 14234.82 MU. Based on allowed sales of 14234.82 MU, the distribution loss comes out to be 24.32% as against 22.45 % indicated by the Discom.

Power Purchase Cost

3.3. Power purchase cost approved by Commission for FY 2013-14 was Rs. 6082 crores vide ARR order dated 06.06.2013. For the purpose of truing up, JdVVNL has claimed Rs. 8017.35 crores as power purchase cost (including short term power purchases and Transmission & SLDC charges).

3.4. Details of power purchase cost as submitted by Discom is given in table below:

Table 1: Power purchase cost submitted by Jodhpur Discom Sr. No. Particulars Units (MU) Amount in

Crores Average

Rate Energy petitioned by Discom 1 Total Energy Purchased by Discom (A) 19917.47 7166.89 3.60

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Sr. No. Particulars Units (MU) Amount in

Crores Average

Rate 2 Less: Purchase From Short term sources (B) 1111.79 352.61 3.17

3 Balance Energy from approved Sources C= (A-B) 18805.68 6814.28 3.62

4 Add: Transmission and SLDC charges (D) 850.46 5 Total Power Purchase claimed (A+D) 8017.35

3.5. The Discom has petitioned that they have purchased 19917.47 MU out of which they have sold 226.98 MU through exchange.

3.6. The Commission has worked out the power purchase requirement based on the approved distribution losses, intra state and interstate transmission losses submitted by the Discom and sales in accordance with approved methodology.

3.7. The Discom has furnished total transmission losses (inter and intra state) in MU terms, therefore, to segregate the same, the Commission has used the intra state losses of 4.2%, and the balance losses based on the material placed by the Discom are considered towards interstate transmission Losses.

3.8. With regard to distribution losses, Stakeholder has submitted that only normative loss will be applied to the energy transmitted on the distribution system of the Discom, i.e., LT to 33 kV system, as the large industrial consumers are being supplied on 132 kV and higher systems. In response to the query raised by the Stakeholder, Discom submitted that the large industrial consumers also exist at 33 kV and 11 kV supply.

3.9. The Commission observes that while fixing the loss target and working out the energy requirement, the Commission has not specified category wise or voltage wise losses but considered these to be overall losses to be loaded on total sales. As such, details of gross energy requirement worked out on the basis of sales as indicated in foregoing para is given in the table below: Table 2: Gross Energy Requirement of JdVVNL for 2013-14 (MUs)

Sr. No.

Particulars

Approved as per Order Dated

06.06.2013

Actual/ Audited

MUs at re-

stated level

Normative Calculatio

n of Energy req.

1 Gross Energy Requirement 16939.00 19917.47 19917.47 18404.49

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Sr. No.

Particulars


06.06.2013

Actual/ Audited

MUs at re-

stated level


n of Energy req.

2 Less:- Sale Through Exchange 226.98 226.98 226.98 3 Net Energy Requirement 16939.00 19690.49 19690.49 18177.51 4 Inter - State Transmission Loss(MUs) 199.00 56.91 56.91 56.91

5 Energy Availability at RVPN (MU) – Total 16739.00 19633.58 19633.58 18120.60

6 Intra - State Transmission Loss (%) 4.20% 4.20% 4.20% 4.20% 7 Intra State Transmission Loss (MUs) 703.00 824.61 824.61 761.07

8 Energy Requirement at Distribution Periphery (MU) 16036.00 18808.97 18808.97 17359.54

9 Distribution Loss (%) 18.00% 22.45% 24.32% 18.00% 10 Distribution Loss (MUs) 2886.00 4222.39 4574.15 3124.72 11 Energy Sales (MUs) 13150 14586.58 14234.82 14234.82

3.10. It is observed that the Discom has purchased 1512.98 MU in excess due to increase in distribution loss over the target given by the Commission.

3.11. As per Regulation 113 (5) of RERC Tariff Regulations, 2009, the losses on account of distribution licensees’ failure to achieve the target set by the Commission be shared in the ratio specified under Regulation 10 for sharing of gains and losses on account of controllable factors.

3.12. The Regulation 10 (2) of RERC Tariff Regulation, 2009 is reproduced below: 10(2) The approved aggregate loss to the Applicant on account of controllable factors shall be dealt with in the following manner: (a) 50% of the amount of such loss may be passed on as an additional charge in tariffs over such period as may be specified in the Order of the Commission under; and (b) The balance amount of loss shall be absorbed by the Applicant. From the reading of Regulation 10(2) above, it is clear that it is at the discretion of the Commission to pass on 50% of such losses as an additional charge in

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tariffs. In the past, the Commission has allowed the sharing of losses. However, looking into the losses which are not reducing despite huge investment, the Commission has decided not to allow sharing of the high losses as done before. The Commission also does not want to burden the consumer on account of Discom’s inefficiency. As such, the Commission disallows 100% of such excess purchase, i.e., 1512.98 MU from actual purchase of 19917.47 MU. Accordingly energy requirement allowed shall be 18404.49 MU.

3.13. No separate account of power purchased under banking arrangement is submitted by Discoms. In view of discussion made later in this order while dealing with prior period expenses, banking transactions are considered as cost neutral and no provision towards notional cost of banking is considered for true up of power purchase cost.

3.14. Discom submitted the total power purchase cost of Rs. 7166.89 crore includes provision for banking. Discom has submitted the banking cost of Rs. 126.91 crore inclusive of Rs. 4.30 crore towards additional transactional cost of banking. However, the Commission has not considered the provision for banking cost and considered only the transaction cost. Accordingly, the Commission has considered the power purchase cost of Rs. 7044.28 crore.

3.15. Details of power purchase cost as approved by the Commission is given in table below:

Table 3: Power purchase cost of JdVVNL approved for FY 2013-14 Sr. No.

Particulars Units (MU)

Amount in Crores

Average Rate

Energy approved by Commission: 1 Total Energy Purchased by Discom (A) 19917.47 7044.28 3.54 2 Less: Disallowed short term sources (B) 1111.79 352.61 3.17

3 Total Energy from approved sources C =(A-B) 18805.68 6691.67 3.56

4 Less: Disallowed approved sources (D) 401.19 142.76 3.56 5 Power Purchase Cost Allowed E=(C-D) 18404.49 6548.91 6 Add: Transmission and SLDC charges (F) 850.46 7 Total Power purchase cost allowed (E+F) 7399.37

3.16. While disallowing the excess purchase of 1512.98 MU by Discom, the Commission

has first considered the power purchase of 1111.79 MU from short term sources

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and the rest 401.19 MU has been considered from approved sources. Thus, the Commission has allowed the gross energy requirement of 18404.49 MU corresponding to the allowed sales.

3.17. Discom has submitted Rs. 850.46 crores as Transmission and SLDC charges which have been allowed as per actual by the Commission. Accordingly, the total power purchase cost including transmission and SLDC charges approved for FY 2013-14 is Rs. 7399.37 crores. Operations and Maintenance (O&M) Expenses

3.18. The O&M expenses approved by the Commission for FY 2013-14 vide Tariff order dated 06.06.2013 were Rs. 536 crores including terminal benefit liability of Rs. 105 crore. For the purpose of true up, JdVVNL has claimed Rs. 1031.84 crores as O&M expenses (including staff terminal benefits based on actuarial valuation of Rs. 618.22 crores).

3.19. Regulation 119 of RERC (Terms & Conditions of Determination of Tariff) Regulations, 2009 provides for O&M expenses as under: a) Employees expenses: 26 paise per unit of sale b) A&G Expenses: 03 paise per unit of sale c) R&M Expenses: 06 paise per unit of sale

3.20. O&M expenses are allowed as per the above norms specified in the Tariff Regulation 2009 for base year 2009-10. The normative charges for FY 2009-10 have been escalated by WPI inflation index as per Regulation 25 (4) of the RERC Tariff Regulations, 2009. The normative charges for FY 2013-14 have been escalated @ 5.98% based on WPI index.

3.21. Details of normative O&M expenses are given in table below: Table 4: O&M Expenses of JdVVNL for 2013-14 (Rs. in crores) Sr. No. Particular Amount in crores

1 Energy Sales approved by Commission (in MU) 14234.82 2 Normative Employee cost for FY 2013-14 (Rs. 0.3531/unit) 502.60 3 Normative A &G expenses (Rs. 0.0407/unit) 57.99

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Sr. No. Particular Amount in crores

4 Normative R&M expenses (Rs. 0.0815/unit) 115.99 5 Less: Proportionate Employee Cost Capitalized 149.72 6 Less: Proportionate A &G cost capitalized (A&G) 13.05 7 Total O&M Expenses Allowed after True up 513.80

Terminal Benefit

3.22. The Commission had approved Rs. 105 crore towards terminal benefit liability in its tariff order dated 06.06.2013. JdVVNL submitted that they have deposited a sum of Rs. 105 crore towards terminal benefit liability. Accordingly, the terminal benefit liability to the extent of actual amount of Rs. 105 crore deposited by the JdVVNL has been considered by the Commission. Depreciation

3.23. The depreciation approved by Commission for FY 2013-14 was Rs. 280 crores vide Tariff order dated 06.06.2013 whereas the Discom has claimed Rs. 242.62 crores as depreciation.

3.24. The Commission has worked out Depreciation as under: a) The closing balance of depreciable assets for the previous year approved by the Commission in the true up order for 2012-13 has been considered as the opening balance for FY 2013-14. The same has been reduced by amount of assets deduction as per audited accounts.

b) Addition to capitalization for current year has been considered as per audited accounts. c) Consumer Contribution and Grants have been considered based on Audited Accounts. d) Average Depreciation rate has been taken as per Discom’s submissions.

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3.25. Details of depreciation charges allowed for FY 2013-14 are given in table below:

Table 5: Depreciation Charges of JdVVNL for 2013-14 (Rs. in crores) Sr. No. Particular Amount in crores

1 Depreciable assets at the beginning of the year (closing balance of FY 2012-13) 5575.27

2 Less: Deductions as per audited accounts 29.31 3 Capitalization during the year 1090.54

4 Less: Capital Outlay financed by Consumer Contribution and grant 407.79

5 Depreciable assets added during the year (3-4) 682.75 6 Closing balance of GFA (1-2+5) 6228.71 7 Average depreciable assets during the year 5901.99 8 Average depreciation rate 3.24% 9 Depreciation Allowed after True up 191.11

Interest and Finance Charges and Interest on Working Capital

3.26. The interest & finance charges approved by Commission for FY 2013-14 were Rs. 1229 crores including interest on working capital as per the ARR order dated 06.06.2013. For the purpose of true up, JdVVNL has claimed Rs. 2800.44 crores as interest and finance charges including interest on working capital.

3.27. Many of the Stakeholders stated that despite huge investment, the performance of Discoms is not improving and instead of reduction in distribution losses the losses are increasing, therefore, the interest charges on such inefficient investment should not be allowed.

3.28. The Commission has considered the issue and finds that the investments are made not only for reduction of losses but are made for various other purposes, viz., system strengthening/ augmentation and improvement, consumer servicing, institutional strengthening, supply to consumers, power evacuation, meeting future load growth and strategic important schemes. The Discoms are also duty bound to develop and maintain an efficient, coordinated, and economical distribution system in their area of supply and also have a duty to supply on request as laid down in Electricity Act, 2003. As stated by many of the Stakeholders, power availability scenario is better in Rajasthan as compared to other States. Moreover, looking to the vast network and efforts to make electricity available to all, necessary investments have to be made. As far as the

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non achievement of losses is concerned, the Commission has already disallowed excess power purchase cost and sharing of distribution losses as discussed in foregoing paras. As such, the Commission accepts the capitalisation as per audited accounts of Discom.

3.29. As per RERC Tariff Regulations, 2009, no short term loans except for working capital can be allowed. The interest and finance charges have been worked out by considering the following:

a) The closing balance of long term loans for previous year approved by the Commission in its order dated 20.02.2015 has been considered as opening balance of long term loans for FY 2013-14.

b) Addition to long term loans during the year has been worked out by reducing the total capitalization by the amount of consumer contribution, capital grants and equity received during the year.

c) Subsequently, an average of opening and closing balance of long term loans after addition of previous year’s is approved revenue gap, i.e., for FY 2012-13, has been considered for calculating the interest charges on long term loans.

d) Repayment has been treated equal to the depreciation allowed for FY 2013-14.

e) Equity, consumer contribution and grants have been considered on the basis of actual. However, equity addition has been capped at 30% of capitalization during the year, if equity infusion during the year is exceeding 30% of capitalization.

f) Finance Charges and interest on security deposit of consumers are allowed as per actual.

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3.30. Commission has allowed interest and finance charges as per the methodology explained earlier. The details are given in table below: Table 6: Interest and Finance Charges of JdVVNL for 2013-14 (Rs. in crores)

Sr. No. Particular Amount in crores

1 Opening balance of Long term Loan (LTL) ( closing balance of FY 2012-13) 2464.40

2 Add: Capitalization during the year 1090.54

3 Less: Capital Outlay financed by Equity (capped at 30% of capitalization during the year) 327.16


5 Addition to LTL for Capital Outlay {2-(3+4)} 355.59 6 Less: Repayments equal to depreciation 191.11 7 Closing balance of LTL (1+5-6) 2628.87 8 Average LTL 2546.64

9 Add: Cumulative Revenue Gap recognized in truing up of FY 2012-13 10221.09

10 Total Long Term Loan Balance to be considered for allowing interest for FY 2013-14 12767.73

11 Average Interest rate of LTL as petitioned 11.24% 12 Interest Charges on LTL 1435.65

13 Interest on security deposit from consumers - As per actual 33.39

14 Finance Charges-As per actual 137.89

15 Total Interest and Finance Charges Allowed after True up ( 12+13+14) 1606.93

3.31. The Commission has approved the interest on working capital on normative basis as per Regulation 28 of RERC Tariff Regulations, 2009. In accordance with Regulation 28 of RERC Tariff Regulations, 2009, for the calculation of gain or loss on account of variation in interest rate, the Commission has considered the difference on account of interest rate submitted by Discom and normative interest rate allowed by the Commission. The details are given below:

a) O&M expenses as approved for FY 2013-14 have been considered for the purpose of calculation of working capital requirement.

b) Receivables have been considered based on the ARR after the true up of FY 2013-14.

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c) The rate of interest on working capital has been taken as 250 basis points higher than the average Base Rate of State Bank of India prevalent during first six months of the previous year as per Fifth Amendment made in Regulation 28 of RERC Tariff Regulations 2009 from 31 August 2012.

d) Amount of security deposit as submitted by Discom has been taken.

3.32. Details of Interest on working capital are given in table below.

Table 7: Interest on Working Capital of JdVVNL for 2013-14 (Rs. in crores)

Sr. No. Particular

Amount considering normative

interest rate

Amount considering interest rate

submitted by Discom

1 O&M expenses of one month 42.82 42.82

2 Maintenance spares @ 15% of operation and maintenance expenses specified in regulation 119;

77.07 77.07

3 Receivables equivalent to one and a half (1½) months billing of consumers

1304.26 1304.26

4 Security deposit from consumers 439.46 439.46 5 Total working capital requirement(1+2+3-4) 984.68 984.68 6 Rate of Interest (SBI PLR Rate) 12.48% 12.94% 7 Interest on working capital allowed after true-up 122.94 127.46

8 Add : 50% Loss arising from variation in Interest rate as per Regulation 28 of RERC Tariff Regulations 2009

2.26

9 Net Interest on working capital 125.20

3.33. It may be seen that loss on account of variation in interest rate is Rs. 4.53 crores. As per Regulation 28 read with Regulation 10 of RERC Tariff Regulations, 50% of the amount of such loss may be passed on as an additional charge in tariffs and the balance amount of loss shall be absorbed by the licensee. Accordingly, 50% of the loss has been added to the amount of interest on working capital worked out on the basis of normative interest rate.

Prior Period Expenses

3.34. JdVVNL has claimed prior period expenses of Rs. 765.61 crore. It has been observed that the major item of the prior period expenses is the “Prior period

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adjustment of power purchase” of Rs. 754.52 crore. The detail of prior period expenses as per audited accounts are as follows:

(Amount in Rs. Crore)

Particulars For the year

ended 31.03.2014

Prior period expenses/loss : Short term Provisions for Power purchase in previous year 754.52 Operating expenses of previous year 2.49 Employees Cost relating to previous year 0.40 Interest & other finance charges relating to previous year 8.03 Material related expenses relating to previous year 0.00 Administrative & general expenses 0.16 11.09

Total 765.61

3.35. While carrying out the true up of any financial year, the Commission allows the capitalization, Operation and Maintenance Expenses, depreciation, interest cost, interest and finance cost as per Tariff Regulations. Hence, expenses of Rs. 11.09 crore on account of above in JdVVNL audited accounts have not been considered as prior period expenses as the Commission has already approved the above expenses in the true up order till FY 2012-13 as per the norms specified in the Tariff Regulations.

3.36. Subsequent to public hearing, the Discoms furnished the item wise details of prior period data relating to power purchase as raised by Stakeholder during the public hearing.

3.37. On perusal of information furnished by Discom towards prior period expense of power purchase of Rs. 754.52 crore, the Commission observed that the above prior period expenses include:

a) The amount of Rs. 53.94 crore which pertains to banking, Rs. 5.06 crore claim towards energy bills and Rs. 84.49 crore towards other expenses:

(i) With regard to (a) Banking of power: the Commission noticed that the Discoms have made a provision towards the year end net liability of banked power. Banking is an arrangement whereby electricity is banked by distribution licensee with other distribution utilities during surplus period with an agreement to receive the same in time of deficit. The banking is a continuous transaction. The principle of banking of energy is that the electricity received is to be returned, even when banked energy is rolled

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over, its return is only postponed. Hon’ble APTEL in appeal no. 220 of 2013 stated as follows: 17. We may further note that the purchase of electricity by the distribution licensee is fully accounted for in the APPC. The electricity received through banking transactions is to be returned by the distribution licensee by purchase in the subsequent year. Such purchase of electricity is accounted towards the APPC of the distribution licensee. If value is given to the electricity received through banking also, it would amount to double counting of electricity whereas the consumers get the benefit of electricity only once. 19. We are unable to accept the appellant’s contention that the quantum of electricity received ought not to be considered by the State Commission for the purpose of calculation of APPC. The State Commission is required to include all sources of power as available with the distribution licensee. The APPC is only a derivative figure and normally the same methodology adopted for approval of the Annual Revenue Requirements and the power purchase cost of distribution licensee needs to be adopted. We may further note that in the present case, the State Commission has already given substantial benefit to the Appellant Association by not considering the contra banking or return banking for the purpose of determination of APPC. The appellant’s contention that banking amounts to storage of electricity and the same cannot be treated as a source of power purchase is also mis-conceived. In the present case, the electricity is actually available to distribution licensee during financial year when it requires the electricity. The said electricity has been accounted for and has been supplied to the consumers but the same ought not to be taken for calculating the total quantum of electricity available with the distribution licensee during the year only for the purposes of calculation of APPC. We may further observe that there can be no notional cost attributed to such banked energy and the cost, if any, has to be included in the total power purchase cost of the distribution licensee when the corresponding electricity is supplied to the third party. In our view, the State Commission has correctly taken the price of the banked energy as available with the distribution licensee/HPSEBL at a zero cost. The banking is a continuous transaction. The principle of banking of energy is that the electricity received by the distribution licensee is to be returned. When the banked energy is rolled over, its return is only postponed. It is not that electricity is not to be received. The quantum of electricity to be returned would only increase in the subsequent years in future to compensate for the roll over and thereby increase the APPC substantially. Since FY 2013-14, Discoms have started accounting for notional cost on closing balance of banked energy and also accounted for notional cost

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of banked energy of FY 2012-13 as prior period provision of power purchase. As explained earlier, the Commission has taken into account only energy quantum of banking transaction without any notional cost. Thus, prior period provision towards banking has not been considered by the Commission.

(ii) Energy Bills: While carrying out the true up of earlier years, the Commission has computed the energy requirement and allowed the power purchase cost accordingly, therefore any claim of prior period energy bills by Discoms are not allowed in the current year, Accordingly the Commission has not accepted the claim towards energy bills. (iii) Other expenses: out of total other expenses of Rs. 84.49 crore, the Commission finds that expenses to the extent of Rs. 22.24 crore towards intercompany transactions, RVPN charges, SLDC charges and rate difference could only be allowed. b) The balance amount of Rs. 611.02 crore pertains to fuel price adjustment, impact of truing up of RVUN and RVPN which are allowed on actual basis. It is submitted by JdVVNL that fuel price adjustments have been done for FY 2010-11 and FY 2011-12. It is also noticed that during the true up FY 2011-12 the per unit power purchase cost of JVVNL, AVVNL and JdVVNL was Rs. 3.18, 3.20, and 2.77 respectively, which shows that the above impact of FPA and true up of RVUN and RVPN was not considered by JdVVNL while finalizing the accounts for FY 2011-12.

3.38. Considering the above, for the purpose of current true up, the Commission has considered the prior period expenses of Rs. 633.26 crore against the JdVVNL’s claim of Rs. 765.60 crore. Other Debits:

3.39. JdVVNL has claimed other debits of Rs. 41.63 crore. It has been observed that the major item of other debit is the CFL distribution expenses of Rs. 40.26 crore. JdVVNL has submitted that expenses on CFL distribution were incurred towards procurement and distribution of CFL. The Government provided subsidy of Rs. 36.40 crore against the same, which has been shown in audited accounts under the head of subsidy received.

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3.40. The Commission has observed that Discoms are required to promote demand side management activities and they have received major amount as subsidy from the Government. As such the Commission has considered the amount of other debits on this account. Notional Revenue

3.41. Some of the Stakeholders pointed out the difference between average billing rate as per Commission’s order dated 06.06.2013 and that submitted by Discom in the true up petition. Stakeholders also apprehended that data of energy sold are not the actual billed energy data but have been manipulated with a view to show less distribution losses. They also requested to disallow such sales.

3.42. In response to above, the Discoms have submitted as follows:

a) The revision of tariff was not applicable for the entire year; therefore, the calculation of charges done by the Stakeholders will not exactly match the approved tariff. Although the tariff order was issued after 2 months of start of the financial year, i.e., in June 2013, the full impact of revised tariff is seen approximately after two months of the issue of the tariff order due to meter reading and billing cycle.

b) That the figures of energy sales were approved on the basis of projection. The energy sale to those consumers who get disconnected during the year does not get reflected in the same. In domestic category in the rural areas, another 10% rebate is being given to the consumers. This further leads to a variation in the approved and actual per unit charges.

c) The Stakeholders seem to have not considered the fact that the approved billing rate as used for calculations is based on the estimated consumption in different slabs across categories whereas the actual consumption may vary across different slabs. It is a common phenomenon that the consumption pattern of the consumers does not remain the same over the whole year.

d) It also happens that a consumer having consumption between 150-300 units in one billing cycle may have a consumption of over 300 units in another billing cycle. So there might be a variation in the slab wise consumption but the category wise total does not change. So the impact of the same has to be given due consideration while comparing the actual and approved figures.

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e) In case of agriculture category, the load is as on March 31st, 2014. It does not present a clear picture of the variation in load over the year which does not remain constant. Some consumers opt for change in load and get their load revised, which also causes a variation in the per unit charges thus calculated.

3.43. During the analysis of sales and revenue as mentioned in the format 2.1 of the

petition, it has been observed that the per unit revenue realization under various categories of consumers are on lower or higher side as compared to the per unit approved tariff. Discoms have contended that the revision of tariff was not applicable for the complete year but the Commission observes that vide order dt. 06.06.13, tariff was increased only for agriculture category consumers and DS & NDS consumers (above 500 units/month,) and to overcome such issues, the Commission vide its last tariff order dt. 20.02.15 directed the Discoms to indicate the sales and revenue figures at both existing and revised tariff separately. The Discoms have furnished these figures in totality without bifurcation. Though there is no provision for disallowing sales in the regulation except where Commission has stipulated a methodology for forecasting sales to any particular tariff category, but looking to consistent comments of the Stakeholders and submission of Discoms, this year the Commission finds it appropriate to take a suitable view on this.

3.44. Having examined the submission of Discoms, the Commission finds that the comparison of per unit actual revenue with the per unit approved tariff would not be tenable as the computation of per unit total revenue including fixed charges and energy charges is dependent on various factors such as actual no. of consumers, connected load and sale, and actual figures of these may be different from what were assumed at the time of projections.

3.45. It has also been observed by the Commission that the comparison of actual fixed charges with the approved fixed charges (in terms of per connection/month or per KW/month or per HP/month) may also not match as Discoms release new connections during the course of the year and, as well, some consumers get disconnected during the year. The number of consumers as reflected in format 2.1 is merely the position of consumers at the year end. Further, the slab of consumers also keeps on changing based on number of units consumed. The connected load as presented in the format 2.1 is merely the position of load at the year end and it does not present a clear picture of the variation in load over the year. Some consumers also opt for change in load

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and get their load revised, which also causes a variation in connected load. Moreover, as stated by Stakeholders, variation in the energy sales figures may lead to understated losses. As such, the Commission deems it appropriate to review the per unit energy charges under various categories of consumers as compared to the per unit approved tariff (energy charges). It has also been observed that the revenue from energy charges in some categories/slabs is on lower side and in some categories/slabs it is on higher side as compared to revenue at energy charges prescribed by the Commission. Therefore, to overcome the above discrepancy the Commission has computed the notional revenue as under:

i. Per unit energy charges have been considered as per order dated 08.08.2012 (for 1st April 2013 to 6th June 2013) and order dated 06.06.2013 (from 7th June 2013 to 31st March 2014).

ii. There was no tariff revision during the period of 12 months of FY 2013-14 in any category except for the agriculture category and new slabs were introduced under domestic and non domestic category, i.e., for consumption above 500 units per month.

iii. The Commission has assumed that the Discom would have realized the revenue as per revised tariff after 30 days. Therefore, instead of computing the weighted average rate for 67 days and 298 days, the Commission has considered 97 days and 268 days. Accordingly, for above categories, the Commission has considered the weighted average of per unit approved energy charges, i.e., for 97 days as per 08.08.2012 tariff order and for 268 days as per 06.06.2013 tariff order.

iv. Actual sales (except agriculture flat rate category) and per unit energy charges under each category were taken while calculating the Notional Revenue.

v. For flat rate category, energy charges have been calculated on the basis of average connected load at which sales are allowed.

vi. As a result of above computation, the total revenue from energy charges based on actual sales and approved energy charges comes out to be Rs.

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5871.04 crore, whereas the Discom under format 2.1 has shown revenue from energy charges as Rs. 5824.26 crore.

vii. The Commission has treated this difference of Rs. 46.78 crore as notional revenue and the gap of Discom has been reduced by such amount which tantamounts to disallowance of gap to that extent.

3.46. Revenue from sale of power, other Income and Non Tariff Income as petitioned

by Discom have been accepted. JdVVNL has reduced the rebate allowed to consumer from the revenue from sale of power.

3.47. Discoms have stated in their accounting policies that Consumer contribution for Service Connection & Line, Capital grants and Subsidies received towards cost of capital assets have not been reduced from the cost of assets. The same has been treated as Deferred Revenue Income which is being amortized/written off in 25 years from the year of its receipt. The depreciation pertaining to such fixed assets is fully charged to revenue.

3.48. However, while computing the depreciation in line with Regulation 20 (2) (b) of RERC Tariff Regulation 2009, the Commission has reduced the capitalization amount funded by the consumer contribution, capital Grant and Subsidy received during the year. Therefore the Commission has not considered the depreciation benefit on such assets and consequently deferred revenue is also not accounted for.

3.49. Based on above discussions and data provided by JdVVNL, prayer of Discom for True-up of the expenditure and revenue for FY 2013-14 based on the actual performance and for approval of the revenue gap of Rs. 5298.91 Cr for the year has not been accepted as petitioned. The Commission has approved the same to the extent shown in following table. Table 8: Summary of True up of JdVVNL for FY 2013-14 (Rs. in crores) Sr. No.

Particulars As per order

dated 06.06.2013

As per petition

Approved After truing up

1 Revenue 2 Sale of power 6418.00 6681.78 6681.78 3 Non-tariff income 265.00 182.23 182.23

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Sr. No.


dated 06.06.2013

As per petition

Approved After truing up

4 Other Income 39.00 53.39 53.39 5 Deferred Revenue Income 0.00 105.01 0.00 6 Income From Trading 0.00 50.17 50.17 7 Prior Period Income 153.35 153.35 8 Total Revenue, A 6722.00 7225.93 7120.92 9 Expenditure

10 Power purchase Cost 6082 8017.35 7399.37 11 O & M Expenses 12 Employee cost 283.00 275.56 352.88 13 A&G expenses 49.00 49.98 44.94 14 R&M expenses 99.00 88.08 115.99 15 Terminal Benefits 105.00 618.22 105.00 16 Depreciation 280.00 242.62 191.11 17 Interest & finance charges 1141.00

2800.44 1606.93

18 Interest on working capital 88.00 125.20 19 Prior Period Expenses 0.00 765.61 633.26 20 Other Debit 41.63 41.63 21 Total Expenditure, B 8127.00 12899.48 10616.32

22 Surplus/(Deficit), C = (A-B) (1,405.00)

(5,673.55)

(3,495.41)

23 Revenue subsidies received from State Government D 438.00 374.63 374.63

24 Revenue gap for FY 2013-14, E =(C-D)

(967.00)

(5,298.91)

(3,120.77)

25 Less: Notional Revenue F 46.78

26 Net: Revenue gap for FY 2013-14, F =(E-F) (5,298.91) (3,073.99)

27 Carry forward of Gap 2012-13 as per Truing up of previous year, G (10,221.09) (10,221.09)

28 Cumulative Revenue Gap to be carried forward, F+G (15,520.01) (13,295.08)

29 Cumulative Revenue Gap till FY 2013-14 (22,590.32)* (13,295.08)

*As per audited accounts

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Analysis of True Up of ARR for FY 2013-14 – JVVNL

Sale of Energy

3.50. The Discom has indicated total sale of 15784.33 MU including 580.92 MU sales to flat rate category. It has been observed that flat rate sales of 580.92 MU are within the limit of normative specific consumption, i.e., 1945 kWh/kW/year as specified by the Commission. As such, Commission accepts the sales of energy as submitted by Discom. Power Purchase Cost

3.51. Power purchase cost approved by Commission for FY 2013-14 was Rs. 7898 crores vide ARR order dated 06.06.2013. For the purpose of truing up, JVVNL has claimed Rs. 9590.17 crores as power purchase cost (including short term power purchases and Transmission & SLDC charges).

3.52. Details of power purchase cost as submitted by Discom is given in the table below: Table 9: Power purchase cost as submitted by Jaipur Discom Sr. No Particulars Units (MU) Amount in

Crores Average

Rate Energy petitioned by Discom 1 Total Energy Purchased by Discom (A) 23180.58 8564.76 3.69

2 Less: Purchase From Short term sources (B) 1223.98 430.66 3.52


4 Add: Transmission and SLDC charges (D) 1025.41

5 Total Power Purchase claimed (A+D) 9590.17

3.53. The Discom has petitioned that they have purchased 23180.58 MU out of which they have sold 276.63 MU through exchange.


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3.55. The Discom has furnished total transmission losses (inter and intra state) in MU

terms, therefore to segregate the same, the Commission has used the intra state losses of 4.2% and the balance losses based on the material placed by the Discom are considered towards interstate transmission Losses.

3.56. Details of gross energy requirement worked out on the basis of sales as indicated in foregoing para is given in the table below: Table 10: Gross Energy Requirement of JVVNL for 2013-14 (MUs)

Sr. No Particulars


06.06.2013

Actual/Audited

MUs at Re-stated

level


n of Energy

req. 1 Gross Energy Requirement 21845.00 23180.58 23180.58 20193.83

2 Less:- Sale of Energy through power exchange 0.00 276.63 276.63 276.63

3 Net Energy Requirement 21845.00 22903.95 22903.95 19917.20 4 Inter State Loss (MU) 247.00 66.19 66.19 66.19

5 Energy Availability at RVPN (MU) – Total 21598.00 22837.76 22837.76 19851.01

6 Intra - State Transmission Loss (%) 4.20% 4.20% 4.20% 4.20%

7 Intra State Transmission Loss (MUs) 907.12 959.19 959.19 833.74


9 Distribution Loss (%) 17.00% 27.85% 27.85% 17.00% 10 Distribution Loss (MUs) 3517.00 6094.24 6094.24 3232.94 11 Energy Sales (MUs) 17173.00 15784.33 15784.33 15784.33

3.57. It is observed that the Discom has purchased 2986.75 MU in excess due to

increase in distribution loss over the target given by the Commission.

3.58. As discussed in earlier paras, the Commission does not wish to burden the consumer on account of Discom inefficiency. As such, Commission disallows 100% of such excess purchase, i.e., 2986.75 MU from actual purchase of 23180.58 MU and accordingly purchase of energy allowed shall be 20193.83 MU.

3.59. Discom submitted the total power purchase cost of Rs.8564.76 crore including

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provision for banking. Discom has submitted the banking cost of Rs. 165.12 crore inclusive of Rs.15.68 crore towards transactional cost of banking. However, the Commission has not considered the provision for banking cost and only the transaction cost of banking is allowed. Accordingly, the Commission has considered the power purchase cost of Rs. 8415.33 crore.

3.60. Details of power purchase cost as approved by the Commission is given in the table below: Table 11: Power purchase cost of JVVNL as approved for FY 2013-14

Sr. No Particulars Units

(MU) Amount in

Crores Average

Rate Energy approved by Commission:

1 Total Energy Purchased by Discom (A) 23180.58 8415.33 3.63

2 Less: Disallowed short term sources (B) 1223.98 430.66 3.52

3 Total Energy from approved sources C =(A-B) 21956.60 7984.67 3.64

4 Less: Disallowed approved sources (D) 1762.77 641.04 3.64

5 Power Purchase Cost Allowed E=(C-D) 20193.83 7343.62

6 Add: Transmission and SLDC charges (F) 1025.41

7 Total Power purchase cost allowed (E+F) 8369.03

3.61. In disallowing the excess power purchase of 2986.75 MU by Discom, the

Commission has first considered the power purchase of 1223.98 MU from short term sources and the rest 1762.77 MU have been considered from the approved sources. Thus, the Commission has allowed the gross energy requirement of 20193.83 MU corresponding to the allowed sales.

3.62. Discom has submitted Rs. 1025.41 crores as Transmission and SLDC charges which have been allowed as per actual by the Commission. Accordingly, the total power purchase cost including transmission and SLDC charges approved for FY 2013-14 is Rs. 8369.03crores.

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Operations and Maintenance (O&M) Expenses

3.63. The O&M expenses approved by the Commission for FY 2013-14 were Rs. 755 crores including terminal benefit liability of Rs. 207 crore vide Tariff order dated 06.06.2013. For the purpose of true up, JVVNL has claimed Rs. 1254.86 crores as O&M expenses (including staff terminal benefits based on actuarial valuation of Rs. 722.93 crores).

3.64. Commission has worked out the normative O&M expenses as per the methodology explained in earlier part of this order. The Normative charges for FY 2013-14 have been escalated @ 5.98% based on WPI as per Regulation 25 (4) of the RERC Tariff Regulations, 2009.

3.65. Details of normative O&M expenses are given in table below: Table 12: O&M Expenses of JVVNL for 2013-14 (Rs. in crores) Sr. No Particular Amount in crores

1 Energy Sales approved by Commission (in MU) 15784.33 2 Normative Employee cost for FY 2013-14 (Rs. 0.3531/unit) 557.31 3 Normative A &G expenses (Rs. 0.0407/unit) 64.31 4 Normative R&M expenses (Rs. 0.0815/unit) 128.61 5 Less: Proportionate Employee Cost Capitalized 174.26 6 Less: Proportionate A &G cost capitalized (A&G) 18.71 7 Total O&M Expenses Allowed after True up 557.26

Terminal Benefit

3.66. The Commission had approved Rs. 207 crore towards terminal benefit liability in their tariff order dated 06.06.2013. However, in reply to data gaps, JVVNL submitted that they have deposited a sum of Rs. 411.50 crore towards terminal benefit liability. Accordingly, the terminal benefit liability to the extent of actual amount of Rs. 411.50 crore deposited by JVVNL has been considered by the Commission.

Depreciation

3.67. The depreciation approved by Commission for FY 2013-14 was Rs. 398 crores vide Tariff order dated 06.06.2013 and Discom has claimed Rs. 426.55 crores as depreciation.

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3.68. The Commission has followed the methodology given earlier in the order for the

calculation of depreciation being allowed.

3.69. Details of depreciation charges allowed for FY 2013-14 are given in table below: Table 13: Depreciation Charges of JVVNL for 2013-14 (Rs. in crores)

Sr. No Particular Amount in

crores






3.70. The interest & finance charges approved by Commission for FY 2013-14 were Rs. 1139 crores including interest on working capital as per the ARR order dated 06.06.2013. For the purpose of true up, JVVNL has claimed Rs. 2827.94 crores as interest and finance charges including interest on working capital.

3.71. Interest and finance charges have been calculated as per the methodology explained earlier. The details are given in table below: Table 14: Interest and Finance Charges of JVVNL for 2013-14 (Rs. in crores) Sr. No Particular Amount in

crores

1 Opening balance of Long Term Loan (LTL) ( closing balance of FY 2012-13) 4780.75




5 Addition to LTL for Capital Outlay {2-(3+4)} 918.38 6 Less: Repayments equal to depreciation 361.32

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Sr. No Particular Amount in

crores 7 Closing balance of LTL (1+5-6) 5337.81 8 Average LTL 5059.28 9 Add: Revenue Gap recognized in truing up of FY 2012-13 10585.83


11 Average Interest rate of LTL as petitioned 11.67% 12 Interest Charges on LTL 1825.54 13 Interest on security deposit from consumers - As per actual 75.00 14 Finance Charges-As per actual 130.00

15 Total Interest and Finance Charges Allowed after True up (12+13+14) 2030.54

3.72. The Commission has approved the interest on working capital as per Regulation

28 of RERC Tariff Regulations, 2009. The details are given in table below:

Table 15: Interest on Working Capital of JVVNL for 2013-14 (Rs. in crores) Sr. No

Particular


interest rate


submitted by Discom


2 Maintenance spares @ 15% of operation and maintenance expenses specified in regulation 119;

83.59 83.59

3 Receivables equivalent to one and a half (1½) months billing of consumers 1468.48 1468.48

4 Security deposit from consumers 758.67 758.67

5 Total working capital requirement(1+2+3-4) 839.84 839.84

6 Rate of Interest (SBI PLR Rate) 12.48% 12.12%

7 Interest on working capital allowed after true-up 104.85 101.76

8 Less: 50% Gain arising from variation in Interest rate as per Regulation 28 of RERC Tariff Regulations, 2009

-1.55


3.73. It may be seen that gain on account of variation in interest rate is Rs. 3.10 crores. As per Regulation 28 read with Regulation 10 of RERC Tariff Regulations, 50% of such gain is to be passed on as a rebate in tariff and the licensee is allowed to retain only 50% of such gain. Accordingly, 50% of the gain has been reduced from the amount of interest on working capital worked out on the basis of normative interest rate.

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Prior Period Expenses

3.74. JVVNL has claimed prior period expenses of Rs 102.06crore. It has been

observed that the major item of the prior period expenses is the “Prior period adjustment of power purchase” of Rs. 98.94 crore. The detail of prior period expenses as per audited accounts are as follows:


Particulars For the year ended 31.03.2014

Prior period expenses/loss Prior Period Adjustment of Power Purchase 98.94 Operating Expenses 1.49 Employee cost 0.25 Interest & Other Financial Charges -4.36 Administration & General Expense 5.39 Material Related Expense 0.34 3.12 Total 102.06

3.75. While carrying out the true up of any financial year, the Commission allows the capitalization, Operation and Maintenance Expenses, depreciation, interest cost and interest on working capital as per Tariff Regulations. Hence, expenses of Rs. 3.12 crore on account of these expenses in JVVNL audited accounts is disallowed as prior period expenses as the Commission has already approved the above expenses in the true up order till FY 2012-13 as per the norms specified in the Tariff Regulations.


3.77. On perusal of information furnished by Discom towards prior period expense of power purchase of Rs. 98.94 crore, the Commission observed that the these prior period expenses include: a) The amount of Rs. 65.74 crore which pertains to banking and Rs. 0.84 crore claim towards energy bills and other expenses:

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(i) Provision of power purchase on account of banking has not been considered as explained earlier. (ii) Energy Bills and other expenses: While carrying out the true up of earlier years, the Commission has computed the energy requirement and allowed the power purchase cost accordingly. Therefore, any claim of prior period energy bills and other expenses by Discoms are not allowed in the current year and accordingly, the Commission has not accepted the above claim. b) The balance amount of Rs. 32.36 pertains to fuel price adjustment, exchange expenses, NTPC charges, RVUN rate difference and RVPN incentive and other charges, which are allowed on actual basis.

3.78. Considering the above, for the purpose of current true up, the Commission has considered the prior period expenses of Rs. 32.36 crore against the JVVNL claim of prior period expenses of Rs. 102.06 crore. Other Debits:

3.79. JVVNL has claimed other debits of Rs. 90.71 crore. It has been observed that the major item of other debit is the CFL distribution expenses of Rs. 39.92 crore, loss due to theft of fixed assets of Rs. 21.64 crore and bad and doubtful debts provision of Rs. 23.25 crore.

3.80. It has been observed by the Commission that the Discom has received subsidy of Rs. 39.60 crore against CFL distribution from Government. As discussed in earlier paras, the Commission has considered the amount of other debits on this account.

3.81. With regard to loss due to theft of fixed assets, JVVNL submitted that the amount of Rs. 21.64 crore shown against theft of fixed asset is the amount not recoverable through insurance as there is no insurance for fixed assets which are in the field. The Commission does not wish to burden the consumer due to inefficient management of fixed assets. Therefore, the Commission has not accepted the claim of Discom of Rs. 21.64 crore towards theft of fixed assets.

3.82. With regard to provision for bad and doubtful debts, JVVNL submitted that the as per the policy of the Discom, provision for doubtful debts is made equivalent

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to 50% of outstanding dues of permanently disconnected consumers which is as per the accounting policies and duly verified by the statutory auditor.

3.83. While carrying out the true up exercise, the Commission has not considered any provision towards bad and doubtful debts. The expenses are allowed only to the extent of debts actually written off by the Discom. Therefore, the Commission has approved the bad debts of Rs. 16.51 Lakh actually written off against the Discom claim of provision of Rs. 23.25 crore towards bad and doubtful debts.

3.84. Thus the Commission has considered the other debits of Rs. 45.99 crore against the Discom claim of Rs. 90.71 crore. Notional Revenue

3.85. The Commission has worked out the Notional Revenue as per the methodology

explained in earlier part of this order.

3.86. The total revenue from energy charges based on actual sales and approved energy charges comes out to be Rs. 7243.16 crore, whereas the Discom under format 2.1 has shown revenue from energy charges as Rs. 7070.55 crore. The Commission has treated this difference of Rs. 172.61 crore as notional revenue and the gap of Discom has been reduced by such amount which tantamount to disallowance of gap to that extent.

3.87. Revenue from sale of power, other Income and Non Tariff Income as petitioned

by Discom have been accepted. JVNNL has shown rebate allowed to consumers separately and the same has been accepted.

3.88. Based on above discussions and data provided by JVVNL, the prayer of Discom

for True-up of the expenditure and revenue for FY 2013-14 based on the actual performance and for approval of the revenue gap of Rs. 5,503.14 Cr for the year has not been accepted as petitioned. The Commission has approved the same to the extent shown in following table:

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Table 16: Summary of True up of JVVNL for FY 2013-14 (Rs. in crores) Sr. No Particulars

As per order dated

06.06.2013 As per petition

Approved After truing

up 1 Revenue 2 Sale of power 9059.00 7788.29 7788.293 Non-tariff income 185.00 210.68 210.684 Revenue through trading (inter Discom) 0.00 61.14 61.145 Deferred Revenue Income 0.00 108.27 6 other Income 78.00 65.08 65.087 Prior period Income 60.28 60.288 Total Revenue, A 9322.00 8293.74 8185.479 Expenditure

10 Power purchase Cost 7898.00 9590.17 8369.0311 O & M Expenses 12 Employee cost 355 354.14 383.0513 A&G expenses 64.00 80.98 45.6014 R&M expenses 129.00 96.81 128.6115 Terminal Benefits 207.00 722.93 411.5016 Depreciation 398.00 426.55 361.3217 Interest & finance charges 1078.00

2827.94 2030.54

18 Interest on working capital 61.00 103.3119 Prior period expenses 102.06 32.3620 Other debits 0.00 90.71 45.9921 Rebate allowed to consumers 47.20 47.2022 Total Expenditure, B 10190.00 14339.49 11958.50

23 Surplus/deficit, C = (A-B) (868.00) (6,045.75) (3,773.03)


25 Revenue gap for FY 2013-14, E =(C-D) (205.00) (5,503.14) (3,230.42)

26 Less: Notional Revenue F 172.61




30 Cumulative Revenue Gap till FY 2013-14 (23,096.51)* (13,643.64) *As per audited accounts

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Analysis of True Up of ARR for FY 2013-14 – AVVNL

Sale of Energy

3.89. The Discom has indicated total sale of 12499.59 MU including 1281.53 MU sales to flat rate category. It has been observed that at the beginning of the year, connected load under flat rate category was 683622 kW and due to conversion of flat rate consumers to metered category, the closing connected load became 631422 kW. The Commission has worked out the sales on the basis of average connected load of 657522 kW and by considering the normative specific consumption, i.e., 1945 kWh/kW/year; the sales to flat rate category shall be 1278.88 MU. Based on the revised sales to flat rate consumer, the total allowed sale of energy is 12496.94 MU. Keeping in view allowed sales of 12496.94 MU, the distribution loss comes out to be 20.70 % as against 20.69 % indicated by the Discom. Power Purchase Cost

3.90. Power purchase cost approved by the Commission for FY 2013-14 was Rs. 5706 crores vide ARR order dated 06.06.2013. For the purpose of truing up, AVVNL has claimed Rs. 7312.09 crores as power purchase cost (including short term power purchase cost and Transmission & SLDC charges).

3.91. Details of power purchase cost as submitted by Discom is given in the table below: Table 17: Power purchase cost submitted by Ajmer Discom Sr. No. Particulars Units

(MU)

Amount in

Crores

Average Rate

Energy petitioned by Discom 1 Total Energy Purchased by Discom (A) 16704.12 6530.06 3.91 2 Less: Purchase From Short term sources (B) 910.10 319.85 3.51


4 Add: Transmission and SLDC charges (D) 782.02 5 Total Power Purchase cost claimed (A+D) 7312.08

3.92. The Discom has petitioned that they have purchased 16704.12 MU out of which

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they have sold 205.70 MU through exchange.


3.94. The Discom has furnished total transmission losses (inter and intra state) in MU terms, therefore to segregate the same, the Commission has used the intra state losses of 4.2% and the balance losses based on the material placed by the Discom are considered towards interstate transmission Losses.

3.95. Details of gross energy requirement worked out on the basis of sales as indicated in foregoing para is given below in table: Table 18: Gross Energy Requirement of AVVNL for 2013-14 (MUs)

Sr. No. Particulars


06.06.2013

Actual/Audited

MUs at re-stated level

Normative

Calculation of

Energy req.

1 Gross Energy Requirement 15832.00 16704.12 16704.12 16559.41 2 Less:- Sale Through Exchange 205.70 205.70 205.70 3 Net Energy Requirement 15832.00 16498.42 16498.42 16353.71

4 Inter State Transmission Loss (MU) 181.00 47.68 47.68 47.68

5 Energy Availability at RVPN (MU) –Total 15651.00 16450.74 16450.74 16306.03

6 Intra State Transmission Loss (%) 4.20% 4.20% 4.20% 4.20%

7 Intra State Transmission Loss(MU) 657.00 690.93 690.93 684.85


9 Distribution Loss (%) 20.00% 20.69% 20.69% 20.00% 10 Distribution Loss (MUs) 2999 3260.22 3262.87 3124.24 11 Energy Sales (MUs) 11995.00 12499.59 12496.94 12496.94

3.96. It is observed that the Discom has purchased 144.71 MU in excess due to

increase in distribution loss over the target given by the Commission.

of 246 RERC 552/15, 553/15, 554/15

3.97. As discussed in earlier paras, the Commission does not want to burden the

consumer on account of Discom inefficiency. As such, Commission disallows 100% of such excess purchase, i.e., 144.71 MU from actual purchase of 16704.12 MU and accordingly purchase of energy allowed shall be 16559.41 MU.

3.98. Discom submitted the total power purchase cost of Rs. 6530.06 crore including provision for banking. Discom has submitted the banking cost of Rs. 122.78 crore inclusive of Rs. 11.66 crore towards transactional cost of banking. However, the Commission has not considered the provision for banking cost and considered only the transaction cost. Accordingly, the Commission has considered the power purchase cost of Rs. 6418.94 crore.

3.99. Details of power purchase cost as approved by the Commission is given in the table below: Table 19: Power purchase cost of AVVNL approved for FY 2013-14

Sr. No. Particulars Units

(MU) Amount in

Crores Average

Rate Energy approved by Commission: 1 Energy petitioned by Discom (A) 16704.12 6418.94 3.84 2 Less: Disallowed short term sources (B) 144.71 50.86 3.51 3 Less: Disallowed approved sources (C) 0.00 0.00 - 4 Power Purchase Cost Allowed D=(A-B-C) 16559.41 6368.09 5 Add: Transmission and SLDC charges (E) 782.02 6 Total Power purchase cost allowed (D+E) 7150.11

3.100. In disallowing the excess purchase of 144.71 MU by Discom, the Commission has

considered the power purchase of 144.71 MU from short term sources. Thus, the Commission has allowed the gross energy requirement of 16559.41 MU corresponding to the allowed sales.

3.101. Discom has submitted Rs. 782.02 crores as Transmission and SLDC charges which have been allowed as per actual by the Commission. Accordingly, the total power purchase cost including transmission and SLDC charges approved for FY 2013-14 is Rs. 7150.11 crores.

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Operations and Maintenance (O&M) Expenses

3.102. The O&M expenses approved by the Commission for FY 2013-14 were Rs. 668 crores including terminal benefit liability of Rs. 181 crore vide ARR order dated 06.06.2013. For the purpose of true up, AVVNL has claimed Rs. 1071.88 crores as O&M expenses (including staff terminal benefits of Rs. 508.45 crores).

3.103. The Commission has worked out the normative O&M expenses as per the methodology explained in earlier part of this order. The Normative charges for FY 2013-14 have been escalated @ 5.98% based on WPI as per Regulation 25 (4) of the RERC Tariff Regulations, 2009.

3.104. Details of normative O&M expenses are given in table below: Table 20: O&M Expenses of AVVNL for 2013-14 (Rs. in crores) Sr. No. Particular Amount in

crores 1 Energy Sales approved by Commission (in MU) 12496.94 2 Normative Employee cost for FY 2013-14 (Rs. 0.3531/unit) 441.24 3 Normative A &G expenses (Rs. 0.0407/unit) 50.91 4 Normative R&M expenses (Rs. 0.0815unit) 101.83 5 Less: Proportionate Employee Cost Capitalized 13.88 6 Less: Proportionate A &G cost capitalized (A&G) 6.09 7 Total O&M Expenses Allowed after True Up 574.01

Terminal Benefit

3.105. The Commission had approved Rs. 181 crore towards terminal benefit liability in their tariff order dated 06.06.2013. In reply to data gaps, AVVNL submitted that they have deposited a sum of Rs. 181 crore towards terminal benefit liability. Accordingly, the terminal benefit liability to the extent of actual amount of Rs. 181 crore deposited by the AVVNL has been considered by the Commission. Depreciation

3.106. The depreciation approved by Commission for FY 2013-14 was Rs. 311 crores vide ARR order dated 06.06.2013 and Discom has claimed Rs. 266.54 crores as

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depreciation charges for the purpose of true up.

3.107. The Commission has followed the methodology given earlier in the order for the calculation of depreciation being allowed.

3.108. Details of depreciation charges allowed for FY 2013-14 are given in table below: Table 21: Depreciation Charges of AVVNL for 2013-14 (Rs. in crores) Sr. No

. Particular Amount in

crores






3.109. The interest & finance charges approved by Commission for FY 2013-14 were Rs. 902 crores including interest on working capital as per the ARR order dated 06.06.2013. For the purpose of true up, AVVNL has claimed Rs. 2938.06 crores as interest and finance charges including interest on working capital.

3.110. Interest and finance charges have been calculated as per the methodology given in table below: Table 22: Interest and Finance Charges of AVVNL for 2013-14 (Rs. in crores) Sr. No.

Particular Amount in crores

1 Opening balance of Long term Loan (LTL) ( closing balance of FY 2012-13) 2835.49

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Sr. No.

Particular Amount in crores




5 Addition to LTL for Capital Outlay {2-(3+4)} 505.34 6 Less: Repayments equal to depreciation 223.25 7 Closing balance of LTL (1+5-6) 3117.58 8 Average LTL 2976.54 9 Add: Revenue Gap recognized in truing up of FY 2012-13 10400.97


11 Average Interest rate of LTL as petitioned 11.83% 12 Interest Charges on LTL 1582.21 13 Interest on security deposit from consumers - As per actual 29.76 14 Finance Charges-As per actual 144.49

15 Total Interest and Finance Charges Allowed after True up (12+13+14) 1756.45

3.111. The Commission has approved the interest on working capital as per Regulation

28 of RERC Tariff Regulations, 2009.

3.112. Details of Interest on working capital are given in table below: Table 23: Interest on Working Capital of AVVNL for 2013-14 (Rs. in crores)

Sr. No. Particular


interest rate


submitted by Discom


2 Maintenance spares @ 15% of operation and maintenance expenses specified in Regulation 119;

86.10 86.10

3 Receivables equivalent to one and a half (1½) months billing of consumers

1239.10 1239.10

4 Security deposit from consumers 532.47 532.47

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Sr. No. Particular


interest rate


submitted by Discom

5 Total working capital requirement(1+2+3-4) 840.56 840.56 6 Rate of Interest (SBI PLR Rate) 12.48% 12.97%

7 Interest on working capital allowed after true-up

104.94 109.02

8 Add : 50% Loss arising from variation in Interest rate as per Regulation 28 0f RERC Tariff Regulations, 2009

2.04


3.113. It may be seen that loss on account of variation in interest rate is Rs. 4.07 crores. As per Regulation 28 read with Regulation 10 of RERC Tariff Regulations, 50% of the amount of such loss may be passed on as an additional charge in tariffs and the balance amount of loss shall be absorbed by the licensee. Accordingly, 50% of the loss has been added to the amount of interest on working capital worked out on the basis of normative interest rate. Prior Period Expenses

3.114. AVVNL has claimed prior period expenses of Rs. 94.01 crore. It has been

observed that the major item of the prior period expenses is the “Prior period adjustment of power purchase” of Rs. 66.97 crore. The details of prior period expenses as per audited accounts are as follows:


Particulars For the year

ended 31 March 2014

Prior period expenses/loss : Short term Provisions for Power Purchase in Previous Years 66.97 Operating Expenses 1.61 Employee Cost 0.88 Depreciation under Provision 0.22 Interest & Other Finance Charges 22.29 Administration Expenses 1.46 Material Related Expenses 0.59 27.05 Total 94.01

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3.115. While carrying out the true up of any financial year, the Commission allows the capitalization, Operation and Maintenance Expenses, depreciation, interest cost, and interest on working capital as per Tariff Regulations. Hence, expenses of Rs. 27.05 crore on account of these in AVVNL audited accounts have not been considered as prior period expenses as the Commission has already approved the above expenses in the true up order till FY 2012-13 as per the norms specified in the Tariff Regulations.


3.117. On perusal of information furnished by Discom towards prior period power purchase of Rs. 66.97 crore, the Commission observed that the above prior period expenses include:

a) A provision of Rs. 48.88 crore towards banking of power, which is not considered by the Commission as per the principle explained in foregoing paras. b) The balance amount of Rs. 18.12 crore pertains to FPA, exchange expenses, NTPC charges, RVUN rate difference and RVPN incentive and other charges, which are allowed on actual basis.

3.118. Considering the above, for the purpose of current true up, the Commission has considered the prior period expenses of Rs. 18.12 crore against the AVVNL claim of prior period expenses of Rs. 94.01 crore. Other Debits:

3.119. AVVNL has claimed other debits of Rs. 82.93 crore. It has been observed that the major item of other debit is the CFL distribution expenses of Rs. 45.34 crore and bad and doubtful debts of Rs. 23.37 crore. It has been observed by the Commission that the Discom has received subsidy against CFL distribution from Government of Rs. 44.00 crore. As discussed in earlier paras, the Commission has considered the amount of other debits on this account.

3.120. With regard to bad and doubtful debts provision, AVVNL submitted that as per the policy of the Discom, provision for doubtful debts is made equivalent to 50%

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of outstanding dues of permanently disconnected consumers which is as per the accounting policies and duly verified by the statutory auditor.

3.121. While carrying out the true up exercise, the Commission has not considered any provision towards bad and doubtful debts. The expenses are allowed only to the extent of debts actually written off by the Discom. Therefore, the Commission has approved the bad debts of Rs. 3.17 crore actually written off against the Discom claim of provision of Rs. 23.37 crore towards bad and doubtful debts.

3.122. Thus, the Commission has considered the other debit of Rs. 62.73 crore against the Discom claim of Rs. 82.93 crore. Notional Revenue

3.123. The Commission has worked out the Notional Revenue as per the methodology explained in earlier part of this order.

3.124. The total revenue from energy charges based on actual sales and approved energy charges comes out to be Rs. 5510.94 crore, whereas the Discom under format 2.1 has shown revenue from energy charges as Rs. 5320.39 crore. This shows that Discom has understated the revenue by Rs. 190.55 crore. The Commission has treated this difference in revenue as notional revenue and reduced the gap of Discom by such amount.

3.125. Revenue from sale of power, other Income and Non Tariff Income as petitioned by Discom have been accepted. AVVNL has reduced the rebate allowed to consumer from the revenue from sale of power.

3.126. Based on above discussions and data provided by AVVNL, prayer of Discom for True-up of the expenditure and revenue for FY 2013-14 based on the actual performance and for approval of the revenue gap of Rs. 4,842.98 Cr for the year has not been accepted as petitioned. The Commission has approved the same to the extent shown in following table:

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Table 24: Summary of True up of AVVNL for FY 2013-14 (Rs. in crores) Sr. No.


dated 06.06.2013

As per petition

Approved After truing

up

1 Revenue 2 Sale of power 6283.00 6055.51 6055.51 3 Non-tariff income 200.00 159.88 159.88

4 Revenue through trading (inter Discom) 0.00 45.46 45.46

5 Deferred Revenue Income 0.00 81.45 0.00 6 Other Income 40.00 41.24 41.24 7 Prior Period Income 0.00 41.68 41.68 8 Total Revenue, A 6523.00 6425.23 6343.78 9 Expenditure

10 Power purchase Cost 5706.00 7312.09 7150.11 11 O & M Expenses 12 Employee cost 352 414.83 427.36 13 A&G expenses 45.00 72.44 44.82 14 R&M expenses 90.00 76.16 101.83 15 Terminal Benefits 181.00 508.45 181.00 16 Depreciation 311.00 266.54 223.25 17 Interest & finance charges 830.00

2938.06 1756.45

18 Interest on working capital 72.00 106.98 19 Prior period expenses 94.01 18.12 20 Other debits 0.00 82.93 62.73 21 Total Expenditure, B 7587.00 11765.51 10072.65 22 Surplus/(Deficit), C = (A-B) (1,064.00) (5,340.29) (3,728.87)


24 Revenue gap for FY 2013-14, E =(C-D) (581.00) (4,842.98) (3,231.56) 25 Less: Notional Revenue F 190.55




29 Cumulative Revenue Gap till FY 2013-14 (23,250.86)* (13,441.98)

*As per audited accounts

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Section 4: Analysis of Investment Plan of Discoms for FY 2015-16

4. Proposed Investment Plan, Analysis and Decisions of the Commission Proposed Investment Plan for FY 2015-16

4.1. The Discoms had proposed investment under various projects/schemes to be executed along with the proposed targets in FY 2015-16 as detailed below:

Table 25: Proposed Investment Plan for FY 2015-16 (Rs. in crores) Sr. No.

Name of schemes JVVNL AVVNL JdVVNL Total

FY 2015-16

FY 2015-16

FY 2015-16

FY 2015-16

A: Plan Works 1 Sub- Transmission & Distribution 470 237 300 1007 2 Rural Electrification Works 275 332 350 957 3 Rajiv Gandhi G.V. Yojna 175 85 150 410 4 R-APDRP-A 54 27 50 130 5 R-APDRP-B/IPDS 111 71 100 282 6 Feeder Improvement Programme 244 100 125 469

7 Sub- Station Improvement Programme 31 30 62 122

8 Mukhya Mantri Sabke Liye Vidyut Yojna 40 25 175 240

9 Deendayal Upadhyaya Gram Jyoti Yojana (DDUGJY) 25 - 50 75

TOTAL (A) 1425 907 1362 3693

4.2. To execute the above work, the Discoms have proposed the funding from following sources:

Table 26: Source wise details of funding for the proposed Capital Investment Plan for FY 2015-16 (Rs. in crore)

Sr. No.

Particulars

JVVNL AVVNL JdVVNL Total

2015-16 2015-16 2015-16 2015-16 1 Loan and Grants (A) 1005 552 897 2454

State Govt. Equity 379 355 464 1199

Equity against MMSLVY 40 - - 40 Total (B) 419 355 464 1239 2 Total (A+B) 1425 907 1362 3693 3 Other than Plan Borrowings 36 36 Total (2+3) 1425 907 1398 3729

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4.3. As given in the table above, Discoms had proposed a total investment of Rs. 1007 crore in FY 2015-16 for sub transmission and distribution infrastructure works. The Discom wise proposed investment and physical targets are provided below:

Table 27: Proposed investment and physical target for FY 2015-16

S.N. Major Heads FY 2015-16 FY 2015-16 FY 2015-16

Units Targets (JVVNL)

Targets (AVVNL)

Targets (JdVVNL)

1. 33/11 KV Substation MVA 320 280 280 Nos. 80 65 70

2. 33 KV Lines KMs 400 350 350

4.4. Discoms submitted that apart from above, investments are required to strengthen the existing network. Accordingly, the system requires further improvement and strengthening so that the system becomes robust and improved and thereby is able to provide quality and reliable supply to the consumer with less number of interruptions. The Discoms also submitted that schemes are also aimed to intensify electrification in the Discom area. The proposed schemes will ensure expansion of the distribution network.

4.5. Discoms also submitted that the above Sub-Transmission & Distribution works include the work of GPVVY scheme. The main features of the GPVVY are as follows:

a) Each Panchayat of the State shall have an independent 11KV feeder covering the villages of the Panchayat.

b) Additional 33/11 KV S/S will be created for a group of 3 to 4 Panchayats at the load centre.

c) The length of 11 KV feeder preferably is not more than 5 Km. d) Each 33/11 KV S/S will have no more than 3 to 4, 11KV feeders for feeding

the villages Panchayat wise. e) 33/11 KV S/S capacity will be such that not more than 80% load comes in

peak season. f) Each 11KV feeder will be restricted possibly to a maximum load of 80

Amps. g) Spans of overhead 11KV line in the rural areas will be reduced by

providing intermittent poles.

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h) Neutral wire shall be drawn for each 1 phase transformer upto 33/11 KV S/S so as to ensure safety of 1 phase system as a consequence of growth in domestic demand of rural areas in future.

4.6. Discoms had proposed a total investment of Rs. 957 crore in FY 2015-16 for rural electrification works which includes electrification, providing electricity connections, improvement of sub transmission and distribution system and reduction of T&D losses in rural areas. The Discom wise proposed investment and physical targets are provided in table given below:

Table 28: Discom wise proposed investment and physical target for RE works in FY 2015-16 S.No. Major Heads

Proposed target

Units JVVNL AVVNL JdVVNL 1 Proposed investment Rs. Crore 275 332 350 2 Domestic Connection Rural Nos 77049 100000 62600

3 Energisation of Wells (Agriculture Connections)

Nos 15221 10000 15000

4.7. JVVNL, AVVNL and JdVVNL had proposed investment of Rs. 175 crore, Rs. 85

crore and Rs. 150 crore respectively in FY 2015-16 for electrification of hamlets with a population of more than hundred people. Implementation of RGGVY includes creation of infrastructure required to electrify the identified villages, hamlets and provision of B.P.L. and A.P.L. connections. The Discoms also submitted that the scheme provides for free of cost connection to all rural households living below poverty line.

4.8. Discoms had proposed total investment of Rs. 412 crore in FY 2015-16 under both RAPDRP-Part A and RAPDRP-Part B. JVVNL, AVVNL and JdVVNL have proposed investment of Rs. 54 crore, Rs. 27 crore and Rs. 50 crore respectively in FY 2015-16 under RAPDRP Part A. Work under R-APDRP Part-A has started and it is expected that execution of scheme under R-APDRP Part-A shall be completed shortly. Further, JVVNL, AVVNL and JdVVNL have also proposed investment of Rs. 111 crore, Rs. 71 crore and Rs. 100 crore under RAPDRP Part B.

4.9. Discoms had proposed total investment of Rs. 591 crore under the flagship schemes namely Feeder Improvement Programme (FIP) and Sub-Station Improvement Programme (SIP) to ensure the uninterrupted quality power supply to all categories of consumers in the State. Besides this, for releasing pending domestic connections to rural households situated in Dhanies /villages having

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population less than 100 under Mukhya-Mantri Sab ke Liye Vidyut Yojna (MMSLVY), investment of Rs. 240 crore have been proposed by the three Discoms.

4.10. On 3rd December, 2014, Government of India has approved the “Deendayal Upadhyaya Gram Jyoti Yojna” (DDUGJY) for which Discoms have proposed total investment of Rs. 75 crore for separation of agriculture and non-agriculture feeders facilitating judicious restoring of supply to agricultural & non-agriculture consumers in the rural areas, strengthening and augmentation of sub-transmission & distribution infrastructure in rural areas, including metering of distribution transformers/feeders/consumers.

4.11. Further, vide letter dated 11.03.2016; the Discoms have submitted the detailed project report of the three Schemes namely RGGVY, DDUGJY and IPDS.

Analysis of the Commission and Decisions:

4.12. The Commission, before finalising the Investment Plan, follows a public consultation process by inviting comments and suggestions of Stakeholders on the petition relating to Investment Plan. The comments and suggestions received from the public are then sent to the Licensees for their views and comments and thereafter the matter is taken up for hearing wherein Stakeholders are offered an opportunity to explain and clarify their comments/suggestions.

4.13. The Commission observes that against the JVVNL, AVVNL and JdVVNL proposal of Rs. 1425 crore, Rs. 907 crore and Rs. 1362 crore respectively, the Discoms have actually incurred Rs. 1483 crore, Rs. 753 and Rs. 1309 crore respectively till February 2016. As the year of investment is already over, the investments actually made are deemed to be approved subject to true-up later.

4.14. The effect of the Investment Plan gets reflected in tariff by way of capitalisation and the Commission while determining ARR & Tariff for 2015-16 has already taken a view on the capitalization proposed by the Discoms for working out ARR. As such, the impact of investment made in FY 15-16 in any case would get reflected only in True-up petitions.

4.15. The Commission observes that substantial investment is being made on the network, but these investments are not giving the desired results. Therefore Discoms should examine each investment carefully and prudently before doing so and unless the investment gives the desired result, the same has to be avoided.

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Section-5: Annual Revenue Requirement

5. Annual Revenue Requirement for FY 2015-16:

5.1 Determination of ARR requires assessment of energy sales as well as cost of various elements like power purchase cost, O&M expenses, interest cost and depreciation, etc. Projection of the Petitioners with respect to various components of ARR, the Commission’s analysis thereon after consideration of views expressed by the Stakeholders and decision with respect to items given below are discussed in the following paras:

(1) Energy sales

(2) Losses, both transmission and distribution

(3) Power purchase cost, including transmission charges and SLDC charges

(4) Operation and maintenance expenses

(5) Interest and finance charges, including interest on working capital

(6) Depreciation

(7) Revenue from existing tariff

(8) Non-tariff and other income

(9) Revenue deficit based on existing tariff

5.2 Energy Sales

5.2.1. Discoms have worked out the energy sales on the basis of the revised estimates of FY 2014-15 as well as actual data for the past years. The consumer category wise sales projected by the three Discoms and the energy sales being approved now by the Commission have been discussed in the following sub-paras.

5.2.2. The Discoms have projected the energy sales for FY 2015-16 for the following consumer categories:

(1) All consumer categories, except agriculture

(2) Agriculture consumers (Metered)

(3) Agriculture consumers (Flat Rate)

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Petitioners’ Submission

5.2.3. Energy Sales for Metered Categories (except Agriculture)

5.2.3.1. The Discoms have submitted that they have worked out energy sales for FY 2015-16 on the basis of historical sales data and revised estimates of sales of FY 2014-15 using the category wise CAGR as per methodology approved by Hon’ble Commission in the previous year’s tariff order. The energy sales from FY 2007-08 to FY 2014-15 have been used for all categories except for agriculture category.

5.2.3.2. For Domestic category, JVVNL and AVVNL have considered 7 year CAGR and JdVVNL has considered 5 year CAGR. Besides the CAGR growth rate, Discoms have stated that they have also kept in view the joint initiative of the Government of India and Government of Rajasthan to provide 24 X 7 power in the State to all consumers (except agriculture consumers) which ensures uninterrupted supply of quality power to existing consumers by the end of 12th Plan and providing access to electricity to all unconnected consumers in the next five years. Under this initiative, Discoms have envisaged to add approximately one lakh consumers per Discom. Accordingly, the three Discoms namely JVVNL, AVVNL and JdVVNL have projected additional sales of 153 MU, 106MU and 99 MU respectively during FY 2015-16.

5.2.3.3. With regard to mixed load category, Discoms stated that negative growth is observed while calculating the CAGR, therefore, for projecting the energy sales of mixed load category, JVVNL and AVVNL have used a nominal growth rate of 5% &1% respectively and JdVVNL has used 7 yr CAGR.

5.2.3.4. Although JVVNL has mentioned that it has considered a nominal growth of 1% on sales of FY 2014-15, however, a growth rate of 15.81% has been observed in electric traction category.

5.2.3.5. The category wise sales projections are available in the following paras.

5.2.4. Energy sales to Agriculture Metered (M) Consumers

5.2.4.1. The energy sales for agriculture metered category have been estimated on the basis of the following factors:

a) Existing Consumers at the start of the Financial Year

b) Addition in the consumers during the Financial Year.

c) Consumers converted from ‘Agriculture Flat’ to ‘Agriculture Metered’ category.

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d) Connected load per consumer.

e) Estimated specific energy consumption.

5.2.4.2. The connected load per consumer has been forecasted based on the trend observed in previous years and the growth anticipated in connected load per consumer due to the decrease in the water table. An escalation of 5% for JVVNL, 3% for AVVNL and 5% for JdVVNL over the connected load of FY 2014-15 has been taken for FY 2015-16.

5.2.4.3. The Discoms submitted that, they have considered the specific consumption of 1939.70 KWh/KW/year for JVVNL, 1722.72 KWh/KW/year for AVVNL and 1995.91 KWh/KW/year for JdVVNL.

5.2.4.4. The Discoms have furnished the following information regarding number of metered consumers, connected load and specific consumption in their petition:

Table 29: Agriculture (M) sales for FY 2015-16-JVVNL

Particulars Consumers

(Nos.)

Connected Load per

consumer (kW)

Total Connected Load (kW)

Specific consumption

(kWh/kW/year)

Consumption (Sales) MU

Existing consumers 402780 6.65 2678487 1939.70 5195

New Consumers 15221 6.65 101220 1939.70 98

Add: converted from flat rate

15000 8.14 122100 1939.70 118

Total 433001 6.70 2901807

5414

Table 30: Agriculture (M) sales for FY 2015-16- AVVNL

Particulars Consumers (Nos.)

Connected Load per

consumer (kW)



(kWh/kW/year)


Existing consumers

347562 6.44 2238299 1722.72 3856

New Consumers 10000 6.44 64400 1722.72 55

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Connected Load per

consumer (kW)



(kWh/kW/year)



15000 10.58 158700 1722.72 137

Total 372562 6.61 2461399

4048

Table 31: Agriculture (M) sales for FY 2015-16- JdVVNL


Connected Load per

consumer (kW)



(kWh/kW/year)


Existing consumers 247425 17.35 4292824 1995.91 8568

New Consumers 15000 17.35 260250 1995.91 260


10000 18.24 182400 1995.91 182

Total 272425 17.38 4735474

9010

5.2.5. Energy Sales for Agriculture Flat Rate (FR) Consumers

5.2.5.1. For forecasting the connected load per consumer for 2015-16, an escalation of 5% for JVVNL, 2% for AVVNL and 5% for JdVVNL over the connected load of FY 2014-15 has been considered.

5.2.5.2. For projecting the sales for agriculture (flat) category for FY 2015-16, Discoms have considered the specific consumption of 1945 KWh/KW/year as approved earlier by the Commission.

5.2.5.3. Discoms indicated the following details regarding the number of flat rate consumers, connected load and specific consumption:

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Table 32: Agriculture (FR) Sales for FY 2015-16 – JVVNL


(Nos.)

Connected Load per

consumer (kW)



(kWh/kW/year)


Existing consumers

36252 8.14 295091 1945 574

Less: converted to meter

15000 8.14 122100 1945 119

Total 21252 8.14 172991

455

Table 33: Agriculture (FR) Sales for FY 2015-16– AVVNL


(Nos.)

Connected Load per

consumer (kW)



(kWh/kW/year)


Existing consumers 58051 10.58 614180 1945 1195


15000 10.58 158700 1945 154

Total 43051 10.58 455480

1040

Table: 34-Agriculture (FR) Sales for FY 2015-16– JdVVNL


(Nos.)

Connected Load per consumer

(kW)



(kWh/kW/year)


Existing consumer 38847 18.24 708569 1945 1378


10000 18.24 182400 1945 177

Total 28847 18.24 526169

1201

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5.2.6. Total energy sales projected by Discoms:

5.2.6.1. The projection of energy sales of different consumer categories discussed in preceding sub-paras is given in the following table: Table: 35- Total Energy Sales for FY 2015-16- Discoms’ Projection (MU)

Particular JVVNL AVVNL JdVVNL Rajasthan Domestic 4,684 3,417 3,237 11,338

Non-Domestic 2,034 1,029 1,019 4,082

Public Street Light 195 80 163 438

Agriculture (Metered) 5,414 4,048 9,011 18,473

Agriculture (Flat) 455 1,040 1,201 2,696

Small Industry 351 300 244 895

Medium Industry 822 845 667 2,334

Large Industry 4,459 2,657 1,305 8,421

Public Water Works (S) 224 252 250 726

Public Water Works (M) 42 39 105 186

Public Water Works (L) 245 170 410 825

Mixed Load / Bulk Supply 201 108 356 664

Electric Traction 169 0 0 169

Total 19,296 13,984 17,968 51,247

Commission’s Analysis

5.2.7. Energy Sales for Metered Categories (except Agriculture Flat Rate Category )

5.2.7.1. Commission in the last year tariff order had considered the energy sales on the basis of 5-year CAGR (from FY 2008-09 to FY 2013-14) for all categories (except Large Industry, Agriculture, Mixed Load and Railway Traction).

5.2.7.2. During the public hearing, a few Stakeholders submitted that as the FY 2015-16 is already ended, it would be proper to take actual sales instead of CAGR approach adopted by the Commission in the last year Order. Subsequent to

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public hearing, the Discoms submitted actual sales and purchase data from April 2015 till January 2016 (10 Months). To estimate the sales for FY 2015-16, the Commission has considered the actual sales from April 2015 to January 2016 (10 months) and further the actual growth rate of last two months of FY 2014-15 (Feb. and March) over the 10 months actual sales (April 14 to Jan. 15) has been applied on actual sales for 10 months of FY 2015-16 to project the sales for 12 month of FY 2015-16 .

5.2.7.3. As the audited figures of sales and purchase of energy for FY 2015-16 are not yet available therefore the Commission has considered the projected figures based on 10 months data as referred to in above para. The Commission will consider the actual figures based on audited accounts while carrying out the true up for FY 2015-16.

5.2.7.4. The category wise metered sales (except flat agriculture) from April 2015 to January 2016 is as follows:

Table 36: Actual Metered Sales for 10 Months (MUs) Particular JVVNL AVVNL JdVVNL Rajasthan

Domestic 3919 2724 2662 9305

Non-Domestic 1726 861 855 3442


Agriculture (Metered) 3956 3011 6494 13461


Medium Industry 616 666 504 1787

Large Industry 3192 1910 982 6084





Electric Traction* - - - -

Total 14416 9958 12766 37140

*In case of JVVNL, sales to electric traction has been considered under Large Industry category

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5.2.7.5. The category wise metered sales (except flat rate agriculture) extrapolated and approved for 12 months of FY 2015-16 is as follows:

Table 37: Actual Metered Sales for 12 Months (MUs) Particular JVVNL AVVNL JdVVNL Rajasthan

Domestic 4,485 3,170 3,037 10692

Non-Domestic 1,952 1,002 989 3943


Agriculture (Metered) 5,311 3,432 8,274 17017


Medium Industry 747 800 602 2149

Large Industry 3,739 2,240 1,179 7157






Total 17,479 11,593 15,598 44670

*In case of JVVNL, sales to electric traction has been considered under Large Industry category

5.2.8. Energy Sales for Agriculture Flat Rate (FR) Consumers

Connected Load per Consumer & Specific Consumption for Flat Rate Consumers

5.2.8.1. The Commission has observed that the Discoms have considered the

connected load per consumer of 8.14 KW for JVVNL, 10.58 KW for AVVNL and 18.24 KW for JdVVNL. The Commission has accepted connected load and number of consumers as filed by Discoms.

5.2.8.2. Further, the Commission has found that Discoms have filed the specific consumption for flat rate consumers as approved by Commission in the order dated 20.02.15 which is accepted by the Commission for FY 2015-16.

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5.2.8.3. Accordingly, the connected load, specific consumption and estimated sales for FY 2015-16 as petitioned by Discoms have been approved by the Commission.

5.2.9. Energy Sales as approved by the Commission for all categories 5.2.9.1. Based on the actual data approach as discussed in the preceding paragraphs

and agriculture flat rate sales, as worked out on the basis of connected load and accepted specific consumption, the energy sales for Discoms are being approved as under:

Table: 38-Energy Sales approved by the Commission for Discoms for FY 2015-16(MU) Particular JVVNL AVVNL JdVVNL Total

Domestic 4,485 3,170 3,037 10,692

Non-Domestic 1,952 1,002 989 3,943


Agriculture (Metered) 5,311 3,432 8,274 17,017

Agriculture (Flat Rate) 455 1040 1201 2696


Medium Industry 747 800 602 2,149

Large Industry 3,739 2,240 1,179 7,157






Total 17,934 12,633 16,799 47,366

*Electric Traction Category has been considered under large industry category

Transmission and Distribution losses

5.3. Distribution Losses

5.3.1. Petitioners’ Submission

5.3.1.1. The Discoms have submitted that they have been able to achieve significant

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loss reduction in past few years through a Feeder Renovation Program initiated in FY 2005-06. Further, Discoms have stated that investments being made under R-APDRP schemes are also expected to aid in the reduction of distribution losses and they are also considering the introduction of distribution franchisees in difficult rural areas with higher losses.

5.3.1.2. For FY 2014-15, JVVNL , AVVNL and JdVVNL submitted the distribution loss as 30.90%, 26.27% and 24.20% respectively based on the provisional figures available with them. For projecting the loss reduction target for FY 2015-16, Discoms have targeted a reduction in Distribution Losses by 4.40%, 4.17% and 3.50% respectively. Accordingly, the JVVNL, AVVNL and JdVVNL have projected the distribution losses of 26.50%, 22.10% and 20.70% respectively for FY 2015-16.

5.3.1.3. The distribution losses as proposed by the petitioners are provided in the table below and this includes technical as well as commercial losses other than those relating to collection efficiency:

Table: 39-Distribution Losses for MYT period 2014-15 and 2015-16 – Petitioners’ Submission

Particulars FY 2014-15 FY 2015-16

JVVNL 30.90% 26.50%

AVVNL 26.27% 22.10%

JdVVNL 24.20% 20.70%


5.3.1.4. For FY 2014-15, Distribution losses as per the trajectory prescribed for the Discoms were 16.09%, 17.65% and 15.13% for JVVNL, AVVNL and JdVVNL respectively. The figures for losses of FY 2014-15 in the petition for FY 2015-16 have been shown at much higher side, i.e., 30.90%, 26.27% and 24.20% as per the latest provisional figures available with the Discoms. For FY 2015-16, Discoms have projected distribution losses at higher side for which no reasons have been provided. It may be observed that adoption of higher loss level would result in corresponding increase in ARR as well as in per unit cost of supply with adverse impact on consumer tariff. Therefore, Commission has decided to adopt the distribution loss trajectory as approved for control period FY 2015-19 in the order dated 20.02.2015.

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5.3.1.5. The distribution losses as approved by the Commission for FY 2015-16 are as under:

Table: 40-Distribution Losses for FY 14-15 and 15-16

Name of Discoms

Losses Approved

by Commission for FY 14-15

Losses Proposed

by Discoms for FY 15-16

Losses Approved by Commission for FY 15-16

JVVNL 16.09% 26.50% 15.19%

AVVNL 17.65% 22.10% 16.36%

JdVVNL 15.13% 20.70% 14.47%

5.4. Collection Efficiency

5.4.1. As Discoms have projected 100% collection efficiency for FY 2015-16. The Commission accepts the submission of Discoms as adoption of lower collection efficiency will increase the revenue gap of Discoms which will indirectly burden the consumers of the State.

5.5. Transmission Losses

5.5.1. The Discoms have considered the intra-state and inter-state transmission loss level for FY 2015-16 based on the provisional loss level figures available for FY 2014-15. The intra-state transmission losses were projected by JVVNL, AVVNL and JdVVNL at 4.2% and inter-state transmission losses at 3.45%.

5.5.2. The levels of transmission losses as proposed by the Discoms have been shown in the following table:

Table41: Levels of Transmission Loss

Particulars Approved by

Commission for FY 2014-15

Proposed for FY 2015-16

Intra-State Transmission Losses-Discoms 4.20% 4.20%

Inter-State Transmission Losses- Discoms 3.45% 3.45%

5.5.3. Commission’s Analysis

5.5.3.1. With respect to intra-state transmission losses, the Commission has adopted transmission losses of 4.15% as per the losses approved by the Commission in

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RVPN transmission tariff order dated 14.08.2015 for FY 2015-16. The Commission has taken the transmission losses outside the State (interstate losses) as average of past 52 weeks for Northern Region and 45 weeks average for Eastern Region as available at NRLDC and ERLDC websites respectively.

5.6 Energy Requirement as approved vis-à-vis Petitioners’ submission 5.6.1. On the basis of the sales and distribution & transmission losses discussed above,

the energy requirement proposed by Discoms and approved by the Commission for FY 2015-16 is given in the following table:

Table 42: Energy Requirement for FY 2015-16 (MU) JVVNL AVVNL JdVVNL Total

Particulars Proposed Approved Proposed Approved Proposed Approved Proposed Approved

Energy Sales to Consumers (MU) 19296 17934 13984 12633 17968 16799 51247 47366

Distribution Loss (%) 26.50% 15.19% 22.10% 16.36% 20.70% 14.47% 23.35% 15.25%

Add: Distribution Loss (MU)

6957 3212 3967 2471 4690 2842 15614 8525

Energy Required at Discoms periphery (MUs)

26253 21146 17951 15105 22658 19641 66862 55891

Intra-State Transmission Losses (%)

4.20% 4.15% 4.20% 4.15% 4.20% 4.15% 4.20% 4.15%

Add: Intra-State Transmission Losses (MU)

1208 916 865 654 1,032 850 3106 2420

Energy Requirement at Transco periphery

27461 22062 18816 15759 23690 20491 69968 58311

Inter-State Transmission Losses (%)

3.45% 3.68% 3.45% 3.68% 3.45% 3.68% 3.45% 3.68%

Add: Inter-State Transmission Losses

298 469 210 328 251 375 758 1172

Gross Energy Requirement (MU)

27759 22531 19026 16087 23941 20867 70726 59484

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5.7. Power Purchase Cost


5.7.1. Discoms have projected energy availability for FY 2015-16 on the basis of estimated generation from existing stations and projected generation from new stations. For existing stations, the Discoms submitted that the power purchase quantum has been considered as per the revised estimates for FY 2014-15 and actual data from previous years. The power purchase from new stations has been considered as per the percentage of share allocated to Rajasthan State. The assumption for PLF and Auxiliary Consumption for new stations is based on the operating norms approved by the appropriate Commission.

5.7.2. Discoms have submitted that they have made the following assumptions while projecting the power purchase cost for FY 2015-16:

• For Coal, Gas and Hydro based Power Plants, an escalation rate of 5% is considered over the per unit actual cost for FY 2014-15.

• For Nuclear Power Plants, the tariff as given in 'Tariff for sale of power from various Atomic Power Stations of NPCIL' compiled by CEA (based on the DAE notifications dated 08-Feb-2012, 25-May-2012 and 22-June-2012 and 23-May-2013) is considered for FY 2015-16.

• The fixed charges and variable charges for the plants which are going to be commissioned in FY 2015-16 have been assumed on the basis of similar types of plant.

• The availability from RFF has been wholly allocated to JVVNL.

• The purchase from renewable energy sources has been projected as per the RPO Obligation approved by the Commission.

5.7.3. Summary of the power purchase quantum and cost as submitted by Discoms in their petitions are as under: Table:43-Power Purchase (MU) and Cost (Rs. Cr.) for FY 2015-16 – submitted by Discoms

STATIONS JVVNL AVVNL JdVVNL TOTAL

MU AMOUNT MU AMOUNT MU AMOUNT MU AMOUNT

NTPC 2237 762 1611 549 1923 655 5770 1965

NHPC 789 288 569 207 679 247 2036 742

NPCIL 1161 342 836 246 998 294 2995 882

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STATIONS JVVNL AVVNL JdVVNL TOTAL

MU AMOUNT MU AMOUNT MU AMOUNT MU AMOUNT

RVUN 12359 4928 8903 3550 10625 4236 31887 12714

RAJWEST 2687 1061 1936 764 2310 912 6933 2738

NVVN 813 386 586 278 699 332 2097 996

SHARED 1277 126 789 35 941 42 3007 203

NCES 2081 987 1499 711 1789 849 5369 2547

OTHERS 5664 1912 4080 1378 4869 1644 14613 4934

TOTAL 29068 10791 20808 7718 24832 9211 74708 27721

Sale of surplus energy

1309 289 1782 394 891 197 3983 880

Net power purchase cost

27759 10502 19026 7325 23941 9014 70726 26840


5.7.4. While estimating energy availability and power purchase cost for 2015-16, the Commission has considered the generation from State and Central generating units based on the ten months actual data submitted by the Discoms as referred to in foregoing paras. Likewise, the position as per latest tariff orders/interim order has also been considered in working out power purchase cost, as discussed later in the order.

5.7.5. For estimating the power purchase cost, the Commission has considered availability from various sources for the State as a whole. For working out Discom wise availability and cost, the allocation of power to JVVNL, AVVNL and JdVVNL from all generating stations has been considered in the ratio of 40%, 28% and 32% respectively, except that 100% allocation of RFF share has been considered for JVVNL.

5.8. Energy Availability and Cost for FY 2015-16

5.8.1. RVUN Stations

5.8.1.1. For existing RVUN generating stations, including KTPS-VII & STPS-VI but excluding Chhabra & Kalisindh, the Commission has considered the energy availability as

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per actual purchase from April 2015 to January 2016, i.e.,10 months of FY 2015-16, which is further extrapolated for 12 months to project the availability for FY 2015-16.

5.8.1.2. The fixed and energy charges for the RVUN plants namely, KTPS, STPS, RGTPS, DCCPP and Mahi are as per RVUN Tariff order dated 07.09.2015 for FY 2015-16.

5.8.1.3. Energy charges of Mini-Micro (MMH) plants have been considered as per Regulation 58 of RERC Tariff Regulations, 2014.

5.8.1.4. The energy availability and cost from RVUN’s generating stations as considered by the Commission have been shown in the table below:

Table: 44- Energy Availability (MU) and Cost (Rs. Cr.)- RVUN Stations for FY 2015-16

Station Energy Availability Cost

KTPS(1 to 7) 6866 2708

STPS(1 to 6) 5387 2403

DCCPP 319 124

RGTPS 462 147

RGTP 3 1038 418

Mahi Hydel Station (Mahi) 66 28

Mini and Micro including Mangrol & STPS Hydel Generating Stations (MMH)

4.92 1.86

Total 14142 5830

5.8.2. Chhabra

5.8.2.1. The availability from CTPP unit 1 & 2, unit 3 and 4 have been considered as per actual purchase from April 2015 to January 2016, i.e., 10 months of FY 2015-16, which is further extrapolated for 12 months to project the availability for FY 2015-16.

5.8.2.2. The variable and fixed charges of unit 1&2 and unit 3 have been considered as per RVUN Tariff order dated 07.09.2015 for unit 1&2 and unit 3.

5.8.2.3. The variable and fixed charges of unit 4 have been considered as per RVUN Provisional Tariff order dated 24.06.2015.

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5.8.2.4. The energy availability and total power purchase cost for Chhabra have been summarized in the table below:

Table 45: Energy Availability (MU) and Cost (Rs. Cr.)- Chhabra Plant for FY 2015-16 Station Energy Availability Total Cost

Chhabra – 1&2 1410 499

Chhabra – 3 1088 416

Chhabra – 4 1274 425

Total 3772 1339

5.8.3. Kalisindh Unit 1 and 2

5.8.3.1. The availability for Kalisindh unit 1& 2 has been considered as per actual purchase from April 2015 to January 2016, i.e., 10 months of FY 2015-16, which is further extrapolated for 12 months to project the availability for FY 2015-16.

5.8.3.2. Further, the fixed and variable charges for unit 1 have been considered as per RVUN Tariff order dated 07.09.2015.

5.8.3.3. The fixed and variable charges for unit 2 have been considered as per interim order dated 21.01.2016.

Table 46: Availability (MU) and Cost (Rs. Cr.) - Kalisindh Unit 1 & 2 Station Energy Availability Total Cost

Kalisindh unit 1 2677 1206

Kalisindh unit 2 423 156

Total 3101 1362

5.8.4. Lignite based projects

5.8.4.1. The lignite based projects include Giral Lignite Power Limited, Rajwest Limited and Barsingsar power project. For Giral unit 1, Commission has not considered any generation for FY 2015-16 as the plant is not functioning for a long period. The availability for Giral II, Rajwest and Barsingsar has been considered as per actual purchase from April 2015 to January 2016, i.e., 10 months of FY 2015-16, which is further extrapolated for 12 months to project the availability for FY 2015-16.

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5.8.4.2. The per unit charge for FY 2015-16 for Giral II have been considered as per the Commission’s interim tariff order dated 31.03.2015.

5.8.4.3. The per unit charge for FY 2015-16 for Rajwest have been considered as per the Commission’s interim tariff order dated 25.01.2016.

5.8.4.4. The fixed and variable charges of Barsingsar project has been considered as per actual purchase from April 2015 to January 2016.

5.8.4.5. The energy availability and total power purchase cost for Lignite based projects have been summarized in the table below:

Table 47: Energy Availability (MU) and Cost (Rs. Cr.)- Lignite Plants for FY 2015-16 Station Energy Availability Total Cost

Giral – 2 233 58

Rajwest 6331 2570

Barsingsar 1099 402

Total 7663 3030

5.8.5. Nuclear Power Corporation of India Ltd. (NPCIL)

5.8.5.1. The Commission has considered the actual purchase from April 2015 to January 2016, i.e., 10 months of FY 2015-16, which is further extrapolated for 12 months to project the availability for FY 2015-16. The variable charge per unit for FY 2015-16 has been considered as per Department of Atomic Energy (DAE) notified rates.

5.8.5.2. The energy availability and total power purchase cost for NPCIL plants have been summarized in the table below:

Table 48: Energy Availability (MU) and Cost (Rs. Cr.)- NPCIL for FY 2015-16 Station Energy Availability Total Cost

NPCIL 3219 918

5.8.6. Partnership Projects (PP)

5.8.6.1. Total power purchase quantum and power purchase cost for partnership projects have been considered as per actual purchase from April 2015 to

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January 2016, i.e.,10 months of FY 2015-16,which is further extrapolated for 12 months to project the availability and cost for FY 2015-16.

5.8.6.2. Energy availability and total power purchase cost for partnership projects have been summarized in the table below:

Table 49: Energy Availability (MU) and Cost (Rs. Cr.)- Partnership Projects for FY 2015-16 Station Energy Availability Total Cost

Partnership Projects 3494 119

5.8.7. NTPC, NHPC & Others

5.8.7.1. The energy availability and charges for NTPC & NHPC plants have been considered as per actual purchase from April 2015 to January 2016, i.e., 10 months of FY 2015-16, which is further extrapolated for 12 months to project the availability and cost for FY 2015-16.

5.8.7.2. The energy availability and charges of Rampur, Aravali, Adani, Sasan, NVVN, SJVVNL, Costal Gujrat, Wangtoo and others plants have been considered as per actual purchase till January, 2016 which is further extrapolated for 12 months to project the availability and cost for FY 2015-16.

5.8.7.3. The energy availability and total power purchase cost for NTPC, NHPC, and other plants have been summarized in the table below:

Table 50: Energy Availability (MU) and Cost (Rs. Cr.)- NTPC & NHPC and Other Generating Stations for FY 2015-16 Plants Energy Availability Total Cost

NTPC Stations 5462 1700 NHPC Stations 1989 607 Other Rampur 174 58 Aravali Power Co. Pvt. Ltd. 8 5 Adani Power Rajasthan Limited 8104 2849 Sasan Power Ltd. 2867 392 SJVVNL 633 176 NVVN Bundled Power 2210 941 Costal Gujarat 2481 594 Karcham Wangtoo (PTC) 507 172

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Plants Energy Availability Total Cost

Tehri Hydro 248 145 Koteshwar 110 41 Tala Through PTC (Bhutan) 58 12 RFF 184 73 Total 25035 7765

5.8.8. Non-Conventional Energy Sources

5.8.8.1. The Commission has observed that the Discoms have submitted higher availability from non-conventional sources as compared to last year. On computation of availability of non-conventional sources based on RPO requirement, it is found to be on higher side than the Discoms’ submission. The Commission has taken the availability from non-conventional energy sources to the extent of RPO requirement, i.e., 7.30% for wind, 0.90% for Bio-mass and 2% for Solar including bundled power.

Cost of Non-Conventional Sources 5.8.8.2. Solar including Bundled Power, Wind and Biomass

The availability has been considered as per RPO and cost has been considered as per actual.

Table 51: Energy Availability (MU) and Cost (Rs. Cr.)-Solar, Wind & Biomass for FY 2015-16

Plants Energy Availability Total Cost

Solar including bundled power 1190 539

Wind 4342 2103

Bio mass 535 341

Total 6067 2982

5.8.8.3. Short term Sources

5.8.8.3.1. After considering the energy available to Discoms based on their respective allocated shares, the Commission has estimated a surplus in energy availability for all the three Discoms.

5.8.8.3.2. Discoms have proposed to sell the surplus power at the rate of Rs. 2.21 per

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unit. In this context, the Commission agrees with the Stakeholders’ concern that the Discoms must try to sell the surplus power at higher rate than the variable charges of thermal generation, for example, STPS variable charges of Rs. 3.73 per unit plus some margin. In light of above fact, the Commission has considered the sale price of surplus power at Rs. 4.00 per unit.

5.8.8.3.3. However, there may have been a situation when Discoms may have resorted to short term power purchase. In that situation, the Regulation 79(6) (a) provides that the Commission shall indicate a tariff for procurement of short term power. Accordingly, the Commission deems it proper to continue with the rate prescribed for this purpose in last year tariff order dt. 20.02.15.

5.9. Total Power Purchase Cost

5.9.1. Based on the above, the summary of source wise and Discom wise breakup of power purchase quantum and cost for 2015-16 as considered by the Commission for the three Discoms is given in the table below:

Table 52: Energy Availability (MU) and Cost (Rs. Cr.) for FY 2015-16

Stations JVVNL AVVNL JdVVNL Total

Units Cost Units Cost Units Cost Units Cost NTPC 2185 680 1529 476 1748 544 5462 1700 NHPC 796 243 557 170 636 194 1989 607 NPCIL 1288 367 901 257 1030 294 3219 918 RVUN/ State Generation 8406 3412 5884 2389 6725 2730 21015 8531 Shared Projects 1398 48 978 33 1118 38 3494 119 Lignite Based Power Plants 3065 1212 2146 849 2452 970 7663 3030 Rampur 70 23 49 16 56 18 174 58 Aravali Power Co. Pvt. Ltd. 3 2 2 1 3 2 8 5 Adani Power Rajasthan Limited 3242 1140 2269 798 2593 912 8104 2849 Sasan Power Ltd. 1147 157 803 110 917 125 2867 392 SJVVNL 253 70 177 49 203 56 633 176 NVVN Bundled Power 884 377 619 264 707 301 2210 941 Costal Gujarat 992 238 695 166 794 190 2481 594 Karcham Wangtoo (PTC) 203 69 142 48 162 55 507 172 Tehri Hydro 99 58 69 41 79 47 248 145 Koteshwar 44 16 31 12 35 13 110 41 Tala Through PTC (Bhutan) 23 5 16 3 18 4 58 12

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Stations JVVNL AVVNL JdVVNL Total

Units Cost Units Cost Units Cost Units Cost RFF 184 73 0 0 0 0 184 73 Non-conventional 2427 1193 1699 835 1942 954 6067 2982 Gross Power Purchase 26708 9382 18567 6516 21219 7447 66493 23346 Less: Surplus Power -4177 -1671 -2480 -992 -353 -141 -7010 -2804 Net Power Purchase 22531 7711 16087 5524 20867 7306 59484 20542

5.10. Transmission Charges


5.10.1. For estimation of the RVPN transmission charges and SLDC charges for FY 2015-16, the escalation rate of 5% is considered over the projected cost of FY 2014-15. Further, for estimating the PGCIL and NRLDC charges, the Discoms have considered an escalation rate of 7.13% over the PGCIL transmission charges and NRLDC charges as payable during FY 2014-15.

5.10.2. The details of the transmission and SLDC charges submitted by Discoms have been summarized in the table below:

Table 53: Transmission Charges & SLDC Charges for 2015-16 (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

PGCIL Charges 328 237 282 847

RVPN Charges 801 577 689 2068

SLDC Charges 16 12 14 42

Total Transmission Charges 1146 825 985 2956


5.10.3. The Commission has considered the RVPN and SLDC charges for FY 2015-16 as per the RVPN and SLDC tariff order dated 14.08.2015 for FY 2015-16 wherein the Commission has approved the Gross ARR for FY 2015-16 of RVPN of Rs. 2478.25 crore and, after accounting of true-up of FY 2013-14 of Rs. 320.73crore, the Commission has considered the net ARR of Rs. 2157.51 crore for FY 2015-16.

5.10.4. Similarly, for SLDC function, the Commission has approved the Gross ARR for FY 2015-16 of Rs. 36.03 crore and, after accounting of true up of FY 2013-14 Rs. 18.38 crore, the Commission has considered the net ARR of Rs. 17.65 crore for FY 2015-16.

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5.10.5. The Commission has considered the PGCIL charges as proposed by Discoms for FY 2015-16.

5.10.6. The transmission & SLDC charges accordingly approved by the Commission for FY 2015-16 are as under:

Table 54: Transmission Charges approved by the Commission for FY 2015-16 (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

PGCIL Charges 328 237 282 847

RVPN Charges 863 604 690 2158

SLDC Charges 7 5 6 18

Total Transmission Charges 1198 846 978 3022

5.11. Operation and Maintenance Expenses


5.11.1. Discoms have estimated O&M expenses based on the O&M norms specified in RERC Tariff Regulations, 2014.

5.11.2. The O&M expenses projected by Discoms for FY 2015-16 have been summarized below:

Table 55: Operation and Maintenance Expenses for FY 2015-16 (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

Employee Costs 776 562 723 2061

Administrative & General Costs 82 59 76 217

Repairs & Maintenance Costs 163 118 152 434

Total O&M Costs 1021 740 951 2712

Less: Expenses to be Capitalized 256 29 208 493

Net O&M Costs charged to revenue 765 711 742 2219


5.11.3. Commission has allowed O&M expenses in accordance with Regulation 83 of RERC Tariff Regulations, 2014.

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5.11.4. The per unit norms for each component for first year of the control period FY 2014-15 are as follows:

• Employee expenses-Rs. 0.38/kWh • A&G expenses-Rs. 0.04/kWh • R&M Expenses –Rs. 0.08/kWh

5.11.5. As per regulation 24(3), the Commission has escalated the O&M expenses at the rate of 5.85% per annum for FY 2015-16.

5.11.6. Commission has considered the sales allowed for FY 2015-16 for projecting normative O&M expenses. Capitalized O&M expenses have been considered in the same ratio as projected by Discoms. O&M expenses approved by the Commission for Discoms for FY 2015-16 have been summarized below:

Table 56: Operation and Maintenance Expenses approved for FY 2015-16 (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

Employee Costs 721 508 676 1905

Administrative & General Costs 76 53 71 201

Repairs & Maintenance Costs 152 107 142 401

Total O&M Costs 949 669 889 2507

Expenses to be Capitalized 238 26 195 459

Net O&M Costs charged to revenue 711 643 694 2048

5.12. Insurance Expenses


5.12.1. Discoms have estimated the Insurance expenses for FY 2015-16 on the basis of net fixed assets subject to the ceiling specified in Regulation 25 of the RERC Tariff Regulations, 2014.

Table 57: Insurance Expenses- Discoms submission for FY 2015-16 (Rs. in Crore)

Particulars JVVNL AVVNL JdVVNL Total

Insurance charges 23 17 17 58

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5.12.2. Commission has allowed Insurance expenses in accordance with Regulation 25 of RERC Tariff Regulations, 2014.

Table 58: Insurance Expenses Approved for FY 2015-16 (Rs. in Crore)


Insurance charges 23 16 15 55

5.13. Terminal Benefit Expenses


5.13.1. The Discoms have considered the terminal benefits as per the provisional figures available for FY 2014-15 and estimated it as a percentage of gross employee expenses other than the additional terminal benefits as per the provisional accounts for the year. This ratio is then applied to projected gross employee expenses for FY 2015-16 for estimating the terminal benefit liability for the year. They have also considered Rs. 300 Cr for the FY 2015-16 as past liability as per the approved Financial Restructuring Plan (FRP).

5.13.2. The terminal benefit liability submitted by the Discoms for FY 2015-16 has been tabulated below:

Table 59: Terminal Benefit Expenses for FY 2015-16 (Rs. crore) Particulars JVVNL AVVNL JdVVNL Total

Terminal Benefit Expenses 414 383 406 1202


5.13.3. The Commission has considered terminal benefit expenses for FY 2015-16 as submitted by Discoms. However, the Commission shall allow the payment made towards actuarial valuation liability in the true up of FY 2015-16 only to the extent of funds actually transferred to the designated fund.

5.14. Capitalization


5.14.1. The capital investment and capitalization proposed by Discoms are shown in the table below:

Table 60: Capital Expenditure and Capitalization proposed for FY 2015-16 (Rs. crores) Particulars JVVNL AVVNL JdVVNL

Capital Expenditure 1425 907 1398

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Particulars JVVNL AVVNL JdVVNL Capitalization 1716 1576 1959


5.14.2. Following the methodology adopted in 20.02.2015 order for FY 2014-15, the Commission has considered 80% of the proposed capitalization in this ARR order.

Table 61: Projected Capitalization approved by the Commission for FY 2015-16 (Rs. Crore)

Particulars JVVNL AVVNL JdVVNL

Capitalization 1373 1261 1567

5.15. Interest on Loans, Lease Rentals and Finance charges


5.15.1. To compute the interest on loan, Discoms have considered opening normative loan as on 1st April 2015 after deducting consumer contribution and normative equity @ 30% of the closing Gross Fixed Assets (GFA) for FY 2014-15. The loan repayment has been considered in accordance with Regulation 21 of the RERC Tariff Regulations 2014 which caps deemed repayments to the depreciation charged for the year. The closing normative loan is considered after deducting normative equity and consumer contribution for FY 2015-16.

5.15.2. The interest on long term loans is estimated on the basis of actual weighted average interest rate for long term loans and applied on the average of normative loans (average of opening and closing normative loan).

5.15.3. The Discoms have projected interest on security deposit on the basis of average of actual security deposit in the previous two years as per provisional accounts for FY 2014-15 and audited accounts of FY 2013-14 and the projected growth in number of consumers. The interest rate has been considered as per the applicable bank rate as applicable during first half of FY 2013-14, i.e., 10.0% plus 250 basis points as per the RERC Tariff Regulations, 2014.

5.15.4. Discoms have projected the finance charges and other borrowing cost to be increased by 5% per annum from provisional accounts for FY 2014-15.

5.15.5. The revenue deficit and interest thereon for FY 2014-15 has been separately shown by the Discoms.

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5.15.6. The interest charges and finance charges for FY 2015-16 have been summarized in the table below:

Table 62: Interest and Financing Charges for FY 2015-16 (Rs. Crore) Descriptions JVVNL AVVNL JdVVNL Total

Opening balance of LTL 9142 6714 6212 22068 Capitalization 1716 1576 1959 5251 Capital expenditure financed by Equity 422 430 464 1317 Capital expenditure financed by Consumer Contribution and grants 149 66 432 647

Receipt of LTL for Capital expenditure 1703 1427 1690 4820 Principal Repayment 507 326 333 1166 Closing balance of LTL 10338 7815 7570 25722 Average LTL 9740 7264 6891 23895 Average Interest rate of LTL (%) 12.36% 11.83% 11.24% Interest Charges on LTL 1204 859 775 2838 Interest on Security Deposit 99 61 50 210 Finance Charges & Lease Rental 169 168 181 518 Gross Interest Charges 1471 1089 1006 3566 Interest Expenses Capitalized 219 108 45 373 Total Interest & Financing Charges 1252 981 961 3194 Carry Forward Gap upto FY 15 17245 16545 17190 50980 Average ROI (as approved by RERC in Tariff Order dated 6/6/2013) 12.36% 11.83% 11.85%

Interest liability on unfunded gap 2132 1957 2037 6126 Total Interest & Financing Charges 3384 2938 2998 9320


5.15.7. The interest and finance charges with respect to the assets capitalized have been calculated by the Commission considering the following:

a) The closing balance of long-term loans for FY 2013-14 allowed in the true-up of FY 2013-14, has been considered by the Commission as the opening balance of FY 2014-15.

b) The capitalization, capital expenditure financed by equity, capital expenditure financed by consumer contribution and grants, receipt of long term loan for capital expenditure and principal repayment for FY 2014-15 have been considered as per order dated 20.02.2015 to arrive at

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the opening balance of loan of FY 2015-16.

c) Capitalization for FY 2015-16 has been considered as discussed in foregoing paragraphs. Since only 80% capitalization has been allowed by the Commission, the equity, consumer contribution and grants have also been taken to the extent of 80% of the total projection by the Discoms.

d) The long-term loans required for capitalization during the FY 2015-16 have been reduced by the amount of consumer contribution, capital grants and equity received during the year.

e) Repayment for FY 2015-16 has been pegged at the depreciation allowed by the Commission for FY 2015-16 as prescribed in the RERC Tariff Regulations, 2014.

f) Unfunded Gap- For computing the carrying cost, the unfunded gap of the true up order of FY 2013-14 and gap as per ARR and Tariff order for FY 2014-15 have been considered.

g) The weighted average interest rate projected by JVVNL, AVVNL and JdVVNL is 12.36%, 11.83% and 11.24% respectively and the same has been accepted by the Commission.

h) Finance charges have been allowed as sought by the three Discoms.

i) Security deposit and interest thereon has been considered as submitted by Discoms.

j) Based on the above, the approved interest and finance charges (with respect to the assets capitalized) approved for FY 2015-16 for the three Discoms have been summarized in the tables below:

Table 63: Interest and Finance Charges approved by the Commission for FY 2015-16 (Rs. Crore)


Opening balance of LTL 5795 3344 3020 12158 Capitalization 1373 1261 1567 4201 Capital expenditure financed by Equity 338 344 371 1053 Capital expenditure financed by Consumer Contribution and grants 119 52 346 517 Receipt of LTL for Capital expenditure 915 865 850 2630

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Particulars JVVNL AVVNL JdVVNL Total Principal Repayment 419 256 242 917 Closing balance of LTL 6292 3952 3628 13872 Average LTL 6043 3648 3324 13015 Average Interest rate of LTL (%) 12.36% 11.83% 11.24% Interest Charges on LTL 747 432 374 1552 Interest on Security Deposit 99 61 50 210 Finance Charges & Lease Rental 169 168 181 518 Gross Interest Charges 1014 661 605 2280 Interest Expenses Capitalized 151 66 27 244 Total Interest & Financing Charges 863 596 578 2036 Carry Forward Gap upto FY 2013-14 as per true up Order for FY 2013-14 13644 13442 13295 40381 Carry Forward Gap of FY 2014-15 as per Commission tariff Order dated 20/02/2015 1156 1256 1670 4082 Interest on Carry Forward Revenue Gap 1829 1739 1682 5250 Total Interest & Financing Charges after interest on carry forward Gap 2692 2334 2260 7286

5.16. Interest on Working Capital


5.16.1. Discoms estimated their working capital requirement for FY 2015-16 as per Regulation 27(3) of the RERC Tariff Regulations, 2014 and the same has been tabulated below:

Table: 64- Interest on Working Capital for FY 2015-16 (Rs. Crore) Descriptions JVVNL AVVNL JdVVNL Total

O&M expenses (as per norms) 98 91 97 287 Maintenance Spare (as per norms) 177 164 172 513 Receivables (as per norms) 2033 1529 1771 5333 Less: Security deposit of Consumers 1017 613 503 2134 Total Working Capital 1291 1171 1537 3999 Interest Rate (%) 12.50% 12.50% 12.50% Interest on Working Capital 161 146 192 500

5.16.2. The Petitioner has further submitted that it has considered the base rate of

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State Bank of India prevalent during first six months of previous year plus 250 basis points as per the Tariff Regulations, 2014 for the purpose of interest on working capital.


5.16.3. The normative working capital requirement along with interest thereon has been calculated by the Commission considering the following:

a) Operation and Maintenance expenses for one month;

b) Maintenance spares @15% of O&M expenses as per Regulation 83 of the RERC Tariff Regulations 2014;

c) Receivables equivalent to one and a half-months billing of consumers;

d) The security deposits of distribution system users (Open Access consumers) and retail supply consumers except the security deposits held as bank guarantees have been deducted from the above to arrive at the total working capital requirement for the year;

e) For the purpose of calculating interest on working capital, the Commission has considered SBI base rate of 10% prevalent during first six months of the previous year plus 250 basis points as per ‘RERC (Terms and Conditions for determination of Tariff) (Fifth Amendment) Regulations, 2012. The rate of interest thus works out to 12.50%.

5.16.4. Accordingly, the interest on working capital considered by the Commission is as under:

Table: 65-Interest on Working Capital approved by the Commission for FY 2015-16 (Rs. Crore)

Descriptions


O&M expenses (as per norms) 59 54 58 171 Maintenance Spare (as per norms) 107 96 104 307 Receivables (as per norms) 1578 1207 1440 4225

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Descriptions


Less: Security deposit of Consumers 1017 613 503 2134 Total Working Capital 727 744 1099 2569 Interest Rate (%) 12.50% 12.50% 12.50% Interest on Working Capital 91 93 137 321

5.17. Depreciation


5.17.1. The Discoms have submitted that they have considered the specified rates as provided in the RERC Tariff Regulations, 2014 in Appendix-I based on Straight Line Method (SLM)

5.17.2. The submission of the three Discoms with respect to depreciation has been tabulated below:

Table: 66-Depreciation for FY 2015-16 (Rs. crore) Particulars JVVNL AVVNL JdVVNL Total

Depreciation 507 326 333 1166


5.17.3. Commission has allowed depreciation based on the following consideration:

• The closing balance of depreciable assets for FY 2013-14 allowed in the True-up Order for FY 2013-14 has been considered by the Commission as the opening balance for FY 2014-15.

• The capitalization during the year, capital expenditure financed by consumer contribution & grants and depreciable assets added during the Year for FY 2014-15 has been considered as per order dated 20.02.2015 to arrive at the opening balance of loan of FY 2015-16.

• For FY 2015-16, capitalization has been considered as discussed earlier.

• Depreciable assets for FY 2015-16 have been reduced by the amount of consumer contribution and capital grants projected for the year.

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Consumer contribution and grant submitted by the three Discoms respectively, for FY 2015-16 has been considered.

• Average depreciation rate has been calculated as a percentage of depreciation during the year on the average of opening and closing GFA submitted by the three Discoms for FY 2015-16.

5.17.4. Deprecation allowed by the Commission for each of the three Discoms has been tabulated below:

Table: 67-Depreciation allowed by the Commission for FY 2015-16 (Rs. Crore)


Depreciable Assets at the beginning of the Year 10978 7593 6862 25432

Capitalization during the year 1373 1261 1567 4201 Less: Consumer Contribution and Capital Grants during the year 119 52 346 517

Depreciable Assets added during the Year 1253 1209 1222 3684

Depreciable Assets at the end of the Year 12231 8802 8083 29116

Average Depreciable Assets during the Year 11604 8197 7472 27274

Average Depreciation Rate 3.61% 3.12% 3.24% Depreciation 419 256 242 917

5.18. Return on Equity


5.18.1. Discoms have submitted that they are incurring heavy financial losses, therefore no return on equity has been proposed for FY 2015-16.

Commission’s Observation 5.18.2. Discoms have not sought Return on Equity so as to restrict the revenue gap. The

Commission has also not considered Return on Equity and this would be in the interest of consumers by minimizing the impact on tariff.

5.19. Non-Tariff Income and Wheeling Charges


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5.19.1. Discoms have projected Non-Tariff Income for FY 2015-16 using the escalation of 5% per annum on the figures of FY 2014-15. Further, No increase has been considered for projecting income from wheeling charges for FY 2015-16 as given below:

Table: 68-Non-Tariff Income for FY 2015-16 (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

Non-Tariff Income 622 432 518 1572

Income from Wheeling Charges 13 7 2 21

Total 635 438 520 1593


5.19.2. The Commission has considered the non-tariff income and wheeling charges for FY 2015-16 as projected by Discoms. The same, therefore, is being allowed.

5.20. Aggregate Revenue Requirement


5.20.1. The Annual Revenue Requirement for FY 2015-16 proposed by the three Discoms has been given in the table below:

Table: 69-Summary of ARR for FY 2015-16 – Discoms’ submission (Rs. Crore) Sr. No. Particulars JVVNL AVVNL JdVVNL Total

1 Power Purchase Cost 10502 7325 9014 26840

2 Transmission Charges

PGCIL 328 237 282 847

RVPN 801 577 689 2068

SLDC 16 12 14 42

3 Operation & Maintenance Expenses 765 711 742 2219

4 Terminal Benefit 414 383 406 1202

5 Interest and Finance Charges 1252 981 961 3194

6 Interest on unfunded gap 2132 1957 2037 6126

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Sr. No. Particulars JVVNL AVVNL JdVVNL Total

6 Interest on working Capital 161 146 192 500

7 Depreciation 507 326 333 1166

8 Insurance charges 23 17 17 58

9 Aggregate Revenue Requirement 16902 12672 14688 44262

10 Less: Non-Tariff Income & Other income 622 432 518 1572

11 Income from Wheeling Charges 13 7 2 21

12 Net Aggregate Revenue Requirement 16267 12233 14168 42668

Commission’s Approval

5.20.2. Commission has approved the ARR for FY 2015-16 based on the items of expenditure discussed in the preceding sections and the same has been summarized in the table below:

Table: 70 Summary of ARR for all the three Discoms for FY 2015-16 – Approved by Commission (Rs. Crore)

Sr.

No. Particulars JVVNL AVVNL JdVVNL Total

1 Power Purchase Cost 7711 5524 7306 20542

2 Transmission Charges

PGCIL 328 237 282 847

RVPN 863 604 690 2158

SLDC 7 5 6 18

3 Operation & Maintenance Expenses

711 643 694 2048

4 Terminal Benefit 414 383 406 1202

5 Interest and Finance Charges 863 596 578 2036

6 Interest on unfunded gap 1829 1739 1682 5250

6 Interest on working Capital 91 93 137 321

7 Depreciation 419 256 242 917

8 Insurance charges 23 16 15 55

9 Aggregate Revenue Requirement 13260 10095 12039 35394

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Sr.

No. Particulars JVVNL AVVNL JdVVNL Total

10 Less: Non-Tariff Income & Other income

622 432 518 1572

11 Income from Wheeling Charges 13 7 2 21

12 Net Aggregate Revenue Requirement

12625 9656 11519 33800

5.21. Revenue and Revenue Deficit based on Existing Tariff


5.21.1. Discoms have projected the revenue from sale of power based on the projected energy sales for different consumer categories. The revenue for each category has been calculated on the basis of retail tariff approved by the Commission vide order dt. 20.02.2015.

5.22. Electricity Duty, Cash Support and Interest Subvention

5.22.1. Discoms have shown electricity duty, transitional cash support and interest subvention and other subsidy for FY 2015-16 as under:

Table: 71–Electricity Duty and Cash support for FY 2015-16 (Rs. Crore) Particular JVVNL AVVNL JdVVNL Total

Differential Interest Subvention on World Bank Loan 4 4 3 11

Subvention from State Govt. against ED/stamp duty 546 401 335 1282.12

Cash Support from State Govt. 185 139 139 463.05

Other Subsidy 11 7 7 25

Total Subsidy Amount 746 551 484 1781

5.23. Revenue on Existing Tariff

5.23.1. The revenue in FY 2015-16 from existing tariff as per Discoms’ submission is as under:

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Table: 72- Revenue from existing tariff for FY 2015-16– Discoms’ submission (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

Domestic Service 2846 2233 1950 7029

Non-Domestic Service 1573 820 817 3210


Agriculture Metered Supply 2576 1930 4150 8655

Agriculture Flat Rate Supply 175 452 517 1144

Small Industrial Service 231 201 164 596

Medium Industrial Service 586 604 484 1674

Large Industrial Service 3468 1981 1103 6552

P.W.W. & S. Pumping –Small 134 153 146 433

P.W.W. & S. Pumping –Medium 28 27 71 126

P.W.W. & S. Pumping –Large 182 119 288 590


Electric Traction 135 135

Total 12191 8648 10028 30867

5.24. Revenue Deficit

5.24.1. The revenue deficits submitted by Discoms for FY 2015-16 at the existing tariff have been provided in the table below:-

Table: 73-Revenue Deficit/Surplus at existing tariff for FY 2015-16 (Rs. Crore) Particulars JVVNL AVVNL JdVVNL Total

Net Aggregate Revenue Requirement 16,267 12,233 14,168 42,668

Revenue from Existing tariff 12,191 8,648 10,028 30,867

Differential Interest Subvention on World Bank Loan 4 4 3 11

Subvention from State Govt. against ED/stamp duty 546 401 335 1,282

Cash Support from State Govt. 185 139 139 463


Deficit including Carrying cost 3,330 3,035 3,656 10,021

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Commission’s Analysis:

5.24.2. Commission has calculated the revenue from existing tariff on the basis of consumer category wise energy sales approved by the Commission in this order for FY 2015-16 and retail tariff as approved by the Commission vide order dt. 20.02.2015. The Commission has worked out revenue at the tariff determined by it, i.e., at revenue based on full tariff. The estimated revenue at existing tariff for different consumer categories for all the three Discoms for FY 2015-16 has been summarized in the table below:

Table: 74- Revenue from Existing Tariff for FY 2015-16- Approved by the Commission (Rs. Crore)

Particular JVVNL AVVNL JdVVNL Total

Domestic Service 2738 2096 1850 6,683

Non-Domestic Service 1532 807 802 3,141


Agriculture Metered Supply 2528 1646 3850 8,024

Agriculture Flat Rate Supply 175 452 521 1,148

Small Industrial Service 220 191 157 568

Medium Industrial Service 536 570 440 1,545

Large Industrial Service 2936 1672 982 5,590

P.W.W. & S. Pumping –Small 139 157 149 446

P.W.W. & S. Pumping –Medium 28 28 70 127

P.W.W. & S. Pumping –Large 191 120 297 608


Electric Traction 0 0 0 0

Total 11,272 7,876 9,452 28,600

5.25. ARR and Revenue

5.25.1. Considering the ARR and Revenue at existing tariff as determined by the Commission and subsidy from Government, Transitional support and other subsidy as shown by Discoms in their petition, the revenue gap for all the three Discoms for FY 2015-16 at the existing tariff has been worked out. Commission

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has carried out true up of RVUN for 2012-13 wherein certain amount has been considered as recoverable by Discoms. Recovery of this amount is considered in 2015-16.

Table: 75-Revenue Deficit/Surplus at existing tariff for FY 2015-16 – Approved by the Commission (Rs. Crore)


Net Aggregate Revenue Requirement 12,625 9,656 11,519 33,800

Revenue from Existing tariff 11,272 7,876 9,452 28,600

Differential Interest Subvention on World Bank

Loan 4 4 3 11

Subvention from State Govt. against ED/stamp

duty 546 401 335 1,282

Cash Support from State Govt. 185 139 139 463


Deficit including Carrying cost 606 1,230 1583 3,419

Add: Consumer Education 0.50 0.50 0.50 1.50

Less: Penalty for Non Conversion of Flat Rate

category 0.05 0.05 0.05 0.15

Net Deficit including Carrying cost 607 1230 1584 3421

Add: Cost recoverable as per RVUN True up

Order FY 2012-13 dated 07.09.2015 -15.14 -10.60 -12.11 -37.85

Net Deficit after considering the true up impact 592 1220 1571 3383

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Section 6-Tariff Proposals and Approved Tariff 6.1. Tariff proposals

6.1.1. Discoms have proposed revision of tariff which would lead to an additional revenue of Rs. 2993 crore during 2015-16 as follows:

Table76: Expected Additional Revenue as proposed by Discoms for FY 2015-16 (Rs. Crore)

Particulars Expected additional revenue

JVVNL 1245

AVVNL 868

JdVVNL 880

Total 2993

6.1.2. As discussed in the foregoing paragraphs, after accounting for the subsidy expected from the State Government, an uncovered gap of Rs. 592 crore, Rs. 1220 crore and Rs. 1571 crores would remain for JVVNL, AVVNL & JdVVNL respectively at the existing tariff. This results in a deficit of Rs. 3383 crores for all Discoms put together for FY 2015-16.

6.1.3. Considering a wide gap between average cost of supply and average realization, revision of tariff becomes a necessary measure.

6.2. Tariff Philosophy

While determining the tariff in this order, the Commission is guided by the principles stated in section 61 of the Electricity Act, 2003 and RERC (Terms and Conditions for Determination of Tariff) Regulations, 2014, which inter-alia provide the following:

• that the distribution and supply of electricity are conducted on commercial basis;

• safeguarding of consumers' interest and at the same time, recovery of the cost of electricity in a reasonable manner;

• that competition, efficiency, economical use of resources, good performance, and optimum investment are encouraged;

• that the tariff progressively reflects the cost of supply of electricity, and also reduces cross subsidies in the manner specified by the Commission;

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• That efficiency in performance is to be rewarded ; and

• That a multi-year tariff framework is adopted.

6.2.1. Section 62(3) of the Act provides that the Appropriate Commission shall not, while determining the tariff under this Act, show undue preference to any consumer of electricity but may differentiate according to the consumer's 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.

6.2.2. The Regulations of the Commission as well as National Tariff Policy visualize cross subsidy to be in +/- 20% range of average cost of supply and this has been considered in the Order.

6.2.3. Therefore, while finalizing the tariff for different consumer categories, the Commission has given due consideration to the relevant provisions of the Act, proposals of the licensees, comments of the Stakeholders, Commission’s decision thereon and the position of cross subsidy.

6.2.4. The tariff has been determined for each category without considering any subsidy. The subsidy, if provided by the Govt., would result in reduced amount payable by consumer of such category. Further, the Government, if it provides subsidy, should pay such subsidy in advance as per RERC (Terms & Conditions for Determination of Tariff) Regulations, 2014.

6.2.5. A large number of Stakeholders in their submissions opposed the proposed tariff hike stating that last four tariff increases were quite steep and the proposed fifth tariff revision in a span of less than four years will put undue burden on consumers.

6.2.6. The Rajasthan DISCOMs are under severe financial stress. The accumulated losses of Discoms have reached to the level of approximately Rs. 90000 crore at the end of FY 2014-15. The outstanding debt level of the DISCOMs has reached Rs. 80530 Crore at the end of September 2015.

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6.2.7. Though Government of India and Government of Rajasthan have initiated UDAY Scheme to bridge this gap and reduce the distribution losses to specified level but effect of that will be visible in the years to come.

6.2.8. There are various reasons for the accumulated losses including high Distribution losses. However, one of the main reasons for accumulation of losses is non increase in tariff for FY 2005-06 to FY 2010-11. Tariff for FY 2011-12 was also made effective in September 2011. To meet the gap of these years, the Discoms had to resort to short terms loans at high interest and every year, the figure kept on increasing.

6.2.9. The Commission, after truing up and disallowing excess losses and expenditure beyond normative levels, has recognized cumulative unfunded gap of Rs. 40381 crore till FY 2013-14 and has allowed carrying cost for this gap.

6.2.10. For FY 2015-16 Discoms projected an ARR of Rs. 42668 Crore and net deficit of Rs. 10021 Crores after receipt of Govt. subsidy at existing tariff. After disallowing excess losses and considering other costs on normative basis, the Commission has determined the net ARR as Rs. 33800 Crores with a net deficit of Rs. 3383 Crores at existing tariff for the full year.

6.2.11. A lot of Stakeholders in their written as well as in oral submissions have submitted that the tariff should not be increased as it has already been increased considerably over last four years. The Commission cannot ignore the financial health of Discoms which has reached an alarming level and if the same is not taken care of at this point of time, it will badly affect Discoms’ capacity to serve consumers and ultimately consumers interests get adversely affected. Major components of Discoms’ cost are power purchase with transmission cost and interest on unfunded revenue gap which constitute approximately 70% and 16% respectively of total cost of Discoms. Needless to point out that this is the share based on the ARR allowed by the Commission based on normative losses and the unfunded gap considered by the Commission. In actual, the ratio of these two costs may be higher because of higher losses and higher accumulated debt. If such a scenario continues, Discoms will not be able to pay generators for the power purchase or may default in service of debt and its repayment. There may also be a situation when the Discoms may face difficulty in paying salaries and pensions. Such a scenario would result in large power cuts and inability of Discoms to maintain Standards of Performance and quality of supply.

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6.2.12. After disallowing excess losses and considering other costs on normative basis, the Commission has determined the net deficit of Rs. 3383 Crores on existing tariff as against Rs. 10021 Crores proposed by Discoms. There is also a huge accumulated unfunded gap of previous years as discussed in foregoing paras.

6.2.13. If the request of the Stakeholders for not increasing the tariff is considered and gap recognized by the Commission even for the FY 2015-16 is not filled at least partially, the Discoms will have to resort to more short term borrowings against this gap which will further add to their interest liability, and unfunded gap will increase exponentially like in previous years when tariff was not increased and efforts being taken to improve performance of Discoms through schemes like UDAY and recent enactment of Rajasthan State Electricity Distribution Management Responsibility Act, 2016 will go in vain.

6.2.14. As discussed in foregoing paras, such non increase of tariff will badly affect the capacity of Discoms to discharge their liability towards generators and for other services rendered to them which is turn will affect the interest of the consumers. Present tariff increase will be effective for only part of the year and even with this tariff increase, the revenue gap of Discoms for FY 2015-16 will not be fully filled up. Though increase in tariff is no pleasure but looking to the present gap in ARR and precarious financial position of Discoms, tariff increase is inevitable at present and the Commission hopes that the people of Rajasthan recognise this and support the efforts of Govt. and the Commission in turning around the Discoms into efficient companies.

6.2.15. Considering the financial and other relevant factors, the Commission has determined the new tariffs as discussed hereinafter. Category wise specific proposals of the Discoms and approval of the Commission are being discussed in the following paras.

Category Wise Tariff

6.3. Domestic Service (LT-1 and HT-1)

6.3.1. Discoms have proposed increase in energy and fixed charges for BPL, small domestic and general domestic consumers.

6.3.2. Discoms have proposed an increase in fixed charges from existing Rs. 90/connection/month to Rs. 100/connection/month for BPL and small

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domestic consumers. Increase in energy charges has been proposed from existing Rs. 3.25 per unit to Rs. 3.50 per unit for BPL consumers and from existing Rs. 3.50 per unit to Rs 3.85 per unit for small domestic consumers.

6.3.3. For general domestic consumers having consumption upto 50 units per month, Discoms have proposed an increase in fixed charges from existing Rs. 180/connection/month to Rs. 200/connection/month. Increase in energy charges has been proposed from existing Rs. 3.50 per unit to Rs. 3.85 per unit.

6.3.4. For general domestic consumers having consumption in the slab of 51-150 units per month, Discoms have proposed an increase in fixed charges from existing Rs. 180 per month to Rs. 200 per month. Increase in energy charges has been proposed from existing Rs. 5.45 per unit to Rs. 6.10 per unit.

6.3.5. For general domestic consumers having consumption in the slab of 151-300 units per month, Discoms have proposed an increase in fixed charges from existing Rs. 200 per month to Rs. 220 per month. Increase in energy charges has been proposed from existing Rs. 5.70 per unit to Rs. 6.40 per unit.

6.3.6. For general domestic consumers having consumption in the slab of 301-500 units per month, Discoms have proposed an increase in fixed charges from existing Rs. 240 per month to Rs. 265 per month. Increase in energy charges has been proposed from existing Rs. 6 per unit to Rs. 6.70 per unit.

6.3.7. For general domestic consumers having consumption above 500 units per month, Discoms have proposed an increase in fixed charges from existing Rs. 260 per month to Rs. 285 per month. Increase in energy charges has been proposed from existing Rs. 6.40 per unit to Rs. 7.15 per unit.

6.3.8. In case of HT domestic category, Discoms have proposed an increase in fixed charges from existing Rs. 170 per KVA per month to Rs. 190 per KVA per month. Increase in energy charges has been proposed from existing Rs. 5.50 per unit to Rs. 6.15 per unit.

6.3.9. The existing tariff, proposed tariff and that approved by the Commission

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are given in the following tables:

Table 77: Existing and Proposed Tariff for Domestic Category for FY 2015-16 Existing Tariff Proposed Tariff

Particulars EC

Subsidy

indicated to be

received

from GoR

Effective EC after subsidy Fixed Charges Particulars Energy Charges (EC) Fixed Charges (FC)

Domestic (DS/LT-1) BPL and Astha Card Holders

Consumption upto first 50 units per

Month

Rs. 3.25 per unit

Rs. 1.90 per unit

Rs. 1.35 per unit

Rs. 90 per connection per

month (Rs. 60/connection/m

onth after subsidy)


Month

Rs. 3.50 per unit Rs. 100 per connection per month

Small Domestic (Consumption up to 50 units per month)**

Consumption up to 50 units per month

Rs. 3.50 per unit

Rs. 1.30 per unit

Rs. 2.20 per unit


month

Consumption up to 50 units per month

Rs. 3.85 per unit Rs. 100 per connection per month

General Domestic – 1 (Consumption upto 150 units per month) General Domestic – 1 (Consumption upto 150 units per month) For consumption upto first 50 units

per Month

Rs. 3.50 per unit --- Rs. 3.50 per

unit Rs. 180 per connection per

month

For consumption upto first 50 units per

Month Rs. 3.85 per unit

Rs. 200 per connection per month For consumption

above 50 units and upto 150 units per

Month


unit

For consumption above 50 units and upto 150 units per

Month

Rs. 6.10 per unit


per Month


unit


month



Rs. 220 per connection per month


Month


unit


Month

Rs. 6.10 per unit

For consumption above150 units and upto 300 units per

Month


unit


Month

Rs. 6.40 per unit


per Month


unit


month


Month

Rs. 3.85 per unit



Month


unit


Month

Rs. 6.10 per unit


Month


unit


Month

Rs. 6.40 per unit



unit


Rs. 6.70 per unit

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Existing Tariff Proposed Tariff

Particulars EC

Subsidy

indicated to be

received

from GoR

Effective EC after subsidy Fixed Charges Particulars Energy Charges (EC) Fixed Charges (FC)

Month Month General Domestic – 4 (Consumption above 500 units per month) General Domestic –4 (Consumption above 500 units per month)

For consumption upto first 50 units

per Month


unit


month





Month


unit


Month

Rs. 6.10 per unit


Month


unit


Month

Rs. 6.40 per unit


Month


unit


Month

Rs. 6.70 per unit

For consumption above500 units per

month


unit

For consumption above500 units per

month Rs. 7.15 per unit

Domestic (DS/ HT-1)

For contract demand above

50 kVA


unit

Rs. 170 per kVA of Billing

Demand per month

For contract demand above

50 kVA Rs. 6.15 per unit

Rs. 190 per kVA of Billing Demand per

month

* Rajasthan Government shall continue to provide adequate subsidy support to BPL, Astha Card holders and Small Domestic consumers Note: The BPL and Astha card Holder domestic tariff shall be exclusively applicable to individual consumer person and shall not be applicable to any institution. In case any BPL, Astha Card Holder and Small Domestic consumers has consumed more than 50 unit per month in any billing cycle, the consumer will be charged as per the applicable tariff of the respective slab under the LT-I domestic category for the additional units consumed. **Subsidy is admissible only if consumption does not exceed 50 units in any month.

Table 78: Domestic Category (LT-1 and HT-1) -Approved tariff for FY 2015-16 Domestic Category

Domestic EC Fixed Charges LT-Domestic ( LT-1)

B P L and Astha card Holders* Consumption upto first 50 units per month

Rs. 3.50 per unit Rs.100 per connection per month

Small Domestic (Consumption up to 50 units/month)*

Consumption up to 50 units/month

Rs. 3.85 per unit Rs.100 per connection per month

of 246 RERC 552/15, 553/15, 554/15

*Note: The BPL and Astha card Holder domestic tariff shall be exclusively applicable to individual consumer person and shall not be applicable to any institution. In case any BPL, Astha Card Holder and Small Domestic consumers has consumed more than 50 unit per month in any billing cycle, the consumer will be charged as per the applicable tariff of the respective slab under the LT-I domestic category for the additional units consumed.

General Domestic (Consumption above 50 units/month)

General Domestic-1 (Consumption upto 150units/month)

Energy Charges Fixed Charges

(i) For consumption upto first 50 units per month Rs. 3.85 per unit

Rs.200 per connection per month (ii) For consumption above 50 units and upto 150 units per month Rs.6.10 per

unit

General Domestic-2 ( Consumption above 150 units and upto 300 units/month )




(ii)For consumption above 50 units and upto 150 units per month Rs.6.10 per unit

(iii)For consumption above 150 units and upto 300 units per month Rs.6.40 per unit

General Domestic-3 (Consumption above 300 and upto 500 units/month)





(iii)For consumption above 150 units and upto 300 units per month Rs.6.40 per unit

(iv)For consumption above 300 units and upto 500 units per month Rs.6.70 per unit

of 246 RERC 552/15, 553/15, 554/15

6.4. Non-Domestic Service (LT-2 & HT-2) :

6.4.1. The fixed charges for consumers upto 5 KW of sanctioned connected load and having consumption in the slab of 0-100 units per month, i.e., Rs. 210/connection/month have been proposed to be increased to Rs. 230/connection/month, whereas increase in energy charges of above slab has been proposed from existing Rs. 6.75 per unit to Rs. 7.55 per unit.

6.4.2. The fixed charges for consumers upto 5 KW of sanctioned connected load and having consumption in the slab of 101-200 units per month, i.e., Rs. 210/connection/month have been proposed to be increased to Rs. 230/connection/month, whereas increase in energy charges of above slab has been proposed from existing Rs. 7.15 per unit to Rs. 8.00 per unit.

6.4.3. The fixed charges for consumers upto 5 KW of sanctioned connected load and having consumption in the slab of 201-500 units per month, i.e., Rs 250/connection/month have been proposed to be increased to Rs. 275/connection/month, whereas increase in energy charges of above slab has been proposed from existing Rs. 7.45 per unit to Rs. 8.35 per unit.

6.4.4. The fixed charges for consumers upto 5 KW of sanctioned connected load

General Domestic-4 (Consumption above 500 units/month)





(iii) For consumption above 150 units and upto 300 units per month Rs.6.40 per unit

(iv)For consumption above 300 units and upto 500 units per month Rs.6.70 per unit

(v)For consumption above 500 units per month Rs.7.15 per unit

HT – Domestic (HT-1)


For contract demand over 50 kVA Rs.6.15 per unit Rs.190/kVA of Billing Demand/month

of 246 RERC 552/15, 553/15, 554/15

and having consumption in the slab above 500 units per month, i.e., Rs 300/connection/month have been proposed to be increased to Rs. 330/connection/month, whereas increase in energy charges of above slab has been proposed from existing Rs. 7.85 per unit to Rs. 8.80 per unit.

6.4.5. The fixed charges for consumers above 5 KW of sanctioned connected load and having consumption in the slab of 0-100 units, 101-200 units and 201-500 units per month, i.e., Rs 85/KW of SCL per month have been proposed to be increased to Rs. 95/ KW of SCL per month, whereas increase in energy charges of above three slabs has been proposed from existing Rs. 6.75 per unit, Rs. 7.15 per unit and Rs. 7.45 per unit to Rs. 7.55 per unit and Rs. 8.00 and Rs. 8.35 per unit respectively.

6.4.6. The fixed charges for consumers above 5 KW of sanctioned connected load and having consumption in the slab of above 500 units per month have been proposed to be increased from Rs 95/KW of SCL per month to Rs. 105/KW of SCL per month, whereas increase in energy charges of above slab has been proposed from Rs. 7.85 per unit to Rs. 8.80 per unit.

6.4.7. The fixed charges for NDS/HT-2 of Rs 170/KVA of billing demand per month have been proposed to be increased to Rs. 190/KVA of billing demand per month, whereas increase in energy charges of above slab has been proposed from Rs. 7.45 per unit to Rs. 8.35 per unit.

6.4.8. Many Stakeholders stated that the proposed tariff for NDS is beyond the limit of +20% of average cost of supply as stipulated in National Tariff Policy and Regulations. The Commission while determining the tariff has kept in view the average cost of supply and realization from this category.

6.4.9. The existing tariff, proposed tariff and that approved by the Commission are given in the following tables:

Table79: Existing and Proposed Tariff for Non-Domestic Category (LT-2 and HT-2) for FY 2015-16


Particulars Energy Charges Fixed Charges Particulars Energy Charges Fixed Charges

Non-Domestic (NDS/LT-2)

NDS upto 5 kW of SCL (Type 1) Consumption upto 100 units per month



month

Rs. 6.75 per unit Rs. 210 per

connection per month




month

of 246 RERC 552/15, 553/15, 554/15







Rs.210 per connection per

month




month Consumption above 100 Units and upto

200 Units per Month Rs. 7.15 per unit

Consumption above 100 Units and upto







month




month









NDS upto 5 kW of SCL (Type 4) Consumption above 500 units per month

NDS upto 5 kW of SCL (Type 4) Consumption above 500 units per month




month




month









Consumption above 500 Units per Month

Rs. 7.85 per unit Consumption above 500 Units per Month

Rs. 8.80 per unit

NDS above 5 kW of Sanctioned Connected Load (LT Supply) Consumption above 500 units per month



Rs. 85 per kW of Sanctioned

Connected Load per month









of 246 RERC 552/15, 553/15, 554/15








Rs. 7.85 per unit



Or

Rs.170 per kVA of Billing Demand per

month (If SCL is more than 18.65

KW)


Rs. 8.80 per unit



Or


month (If SCL is more than 18.65

KW)

Non Domestic (NDS/HT-2) (For Contract Demand over 50 kVA)

All units Rs. 7.45 per unit Rs.170 per kVA of Billing Demand per

month All units Rs. 8.35 per unit


month

Table 80: Non-Domestic Category (LT-2 and HT-2) –Approved tariff for FY 2015-16

NDS up to 5 KW of Sanctioned Connected Load

LT-NDS(LT-2)

Type 2 Consumption above 100 units/month and upto 200 units/month)


Consumption upto first 100 units per month Rs.7.55 per unit Rs 230 per connection per month

Consumption above 100 units and upto 200 unit per month

Rs.8.00 per unit

LT-NDS(LT-2)

Type1 (Consumption upto 100 units/month)


Consumption upto first 100 units per month Rs. 7.55 per unit


of 246 RERC 552/15, 553/15, 554/15

LT-NDS(LT-2)

Type 3 (Consumption above 200 units and upto 500 units/month)


Consumption upto first 100 units per month Rs.7.55 per unit


Consumption above 100 units and upto 200 units per month

Rs.8.00 per unit


Rs. 8.35 per unit

LT-NDS(LT-2)

Type 4 (Consumption above 500 units/month)





Rs.8.00 per unit


Rs. 8.35 per unit

Consumption above 500 unit per month Rs. 8.80 per unit

NDS above 5 KW of Sanctioned Connected Load NDS above 5 KW of SCL (LT-2)



Rs. 95 per kW of Sanctioned Connected Load per month


Rs.8.00 per unit

Consumption above 200 unit and upto 500 units per month

Rs. 8.35 per unit

Consumption above 500 units per month Rs. 8.80 per unit Rs. 105 per kW of Sanctioned Connected Load per month Or Rs. 190 per kVA of Billing Demand per month (If SCL is more than 18.65 KW)

HT-NDS (HT-2)

For contract demand over 50 KVA

All units Rs. 8.35 per unit Rs.190 per kVA of Billing Demand per

month

of 246 RERC 552/15, 553/15, 554/15

6.5. Public Street Lighting Service (LT-3)

6.5.1. Discoms have proposed to raise tariff for public street lighting for both areas with less than 1 lakh population and more than 1 lakh population.

6.5.2. Discoms have proposed an increase in fixed charges from Rs. 75/lamp point/month to Rs.85/lamp point/month subject to a maximum of Rs. 850 per service connection per month for areas with population less than 1 lakh and from Rs. 95/lamp point/month to Rs. 105/lamp point/month subject to a maximum of Rs. 2100 per service connection per month for areas with population greater than 1 lakh.

6.5.3. They have also proposed an increase in energy charges from Rs. 5.85 per unit to Rs. 6.55 per unit for areas with population less than 1 lakh and from Rs. 6.30 per unit to Rs. 7.05 per unit for areas with population greater than 1 lakh.

6.5.4. The existing tariff, proposed tariff and that approved by the Commission are given in the following tables.

Table 81: Existing and Proposed Tariff for Public Street Lighting (LT-3) Category for FY 2015-16

Existing Tariff Proposed Tariff Particulars Energy Charges Fixed Charges Particulars Energy Charges Fixed Charges

Population <1

Lakh Rs. 5.85 per unit

Rs. 75 per Lamp point per month

subject to a maximum of Rs. 750

per service connection per

month

Population <1

Lakh Rs. 6.55 per unit


subject to a maximum of Rs. 850

per service connection per

month

Population =

>1 Lakh Rs. 6.30 per unit


subject to a maximum of Rs. 1900 per service


Population =

>1 Lakh Rs. 7.05 per unit


subject to a maximum of Rs. 2100 per service


Table 82: Public Street Lighting (LT-3) Category-Approved Tariff for FY 2015-16 Particulars Energy Charges Fixed Charges Population <1 Lakh

Rs. 6.55 per unit Rs. 85 per Lamp point per month subject to a maximum of Rs. 850 per service connection per month

Population = >1 Lakh

Rs. 7.05 per unit Rs. 105 per Lamp point per month subject to a maximum of Rs. 2100 per service connection per month

6.6. Agriculture Supply (LT-4)

6.6.1. Discoms have proposed to increase the existing energy charges from Rs.

of 246 RERC 552/15, 553/15, 554/15

4.50/unit to 4.75/per unit for agriculture consumers getting supply in block hours and from Rs. 5.70/unit to 6.05/unit for all others getting supply more than block hours.

6.6.2. For flat rate consumers, the Discoms have proposed to increase energy charges from Rs. 600/ HP/month to Rs. 635/ HP /month for general consumers getting supply in block hours and from Rs. 720/ HP/month to 765/ HP/month for consumers getting supply more than block hours.

6.6.3. Discoms have not proposed any change in the fixed charges of both metered and flat rate consumers.

6.6.4. The existing and the proposed tariff for agriculture supply are summarized below:

Table 83: Agriculture Category (LT-4) — Existing and Proposed Tariff for FY 2015-16 Existing Tariff Proposed Tariff

Particulars EC

Subsidy

indicated to be

received

from GoR

Effective EC after subsidy

Fixed Charges Particulars Energy

Charges (EC) Fixed

Charges (FC)

Agriculture Metered Category (AG/ MS/LT-4)

General (getting supply in block hours)

Rs. 4.50 per unit

Rs. 3.60 per unit

Rs. 0.90 per unit

Rs.15 per HP per Month of SCL Maximum

Rs 250 per month per consumer (Subsidy

above Rs 45 per

Connection per Month )

General (getting supply in block hours)

Rs. 4.75 per unit

Rs.15 per HP per Month of SCL Maximum

Rs 250 per month per consumer

All others not covered under items (i) and

getting supply more than block hours

Rs. 5.70 per unit

Rs 3.60 per unit

Rs 2.10 per unit

Rs.30 per HP per month of SCL Maximum

Rs. 500 per month per consumer (Subsidy

above Rs 50 per

Connection per Month )

All others not covered under items (i) and

getting supply more than

block hours

Rs. 6.05 per unit

Rs.30 per HP per month of SCL Maximum

Rs. 500 per month per consumer

of 246 RERC 552/15, 553/15, 554/15

Agriculture Flat Rate Category (AG/ FR/LT-4)


Particulars EC

Subsidy

indicated to be

received

from GoR


Fixed Charges

Particulars Energy Charges (EC)

Fixed Charges (FC)

General (getting

supply in block hours)

Rs. 600 per HP per Month



Rs.15 per HP per month of

SCL Maximum Rs

250 per month per consumer (Subsidy above

Rs 15 per Connection per Month)

General (getting

supply in block hours)



SCL Maximum Rs

250 per month per consumer

All others not covered

under items (i) and getting supply more than block

hours





SCL Maximum Rs

500 per month per consumer (Subsidy above

Rs 20 per Connection per Month)

All others not covered under items

(i) and getting

supply more than block

hours



SCL Maximum Rs

500 per month per consumer

* Rajasthan Government shall continue to provide adequate subsidy support to Agriculture Metered & Flat Rate consumers

6.6.5. Accordingly, the tariff determined by the Commission for this category is as under:

Table 84: Agriculture Category (LT-4)-Approved Tariff for FY 2015-16 Agriculture Supply Energy Charges (EC) Fixed Charges

Metered (AG/MS/LT-4)

(i) General (getting supply in block hours)

Rs. 4.75 per unit

Rs.15 per HP per

Month of SCL

(ii)All others not covered under items (i) and getting supply more than block hours

Rs. 6.05 per unit

Rs.30 per HP per Month of SCL

of 246 RERC 552/15, 553/15, 554/15

Agriculture Supply Energy Charges (EC) Fixed Charges

Flat/ unmetered (AG/FR/LT-4)

(i)General (getting supply in block hours) Rs. 635 per HP per Month

Rs. 15 per HP per month of SCL

(ii)All others not covered under items (i) above and getting more than block hour supply

Rs 765 per HP per Month

Rs. 30 per HP per month of SCL

6.7. Small Industries (LT-5)

6.7.1. Discoms have proposed an increase in energy charges from Rs. 5.35 per unit to Rs. 6.00 per unit for consumption upto 500 units per month and from Rs. 5.75 per unit to Rs. 6.45 per unit for consumption above 500 units per month.

6.7.2. The fixed charges have been proposed to be uniformly increased for all consumers from Rs. 60/HP/month of sanctioned connected load to Rs.65/HP/month of sanctioned connected load as under:

6.7.3. The existing tariff, proposed tariff and that approved by the Commission are given in the following tables.

Table 85: Small Industries (LT-5)-Existing and Proposed Tariff for FY 2015-16 Existing Tariff Proposed Tariff

Particulars Energy Charges Fixed Charges Particulars Energy Charges Fixed Charges Small Industrial Service (LT-5) (Load not exceeding 18.65 kW (25HP)

Upto 500 units Rs. 5.35 per unit Rs. 60 per HP per

month of sanctioned connected load

Upto 500 units Rs. 6.00 per unit Rs. 65 per HP per


Above 500 units Rs. 5.75 per unit Rs. 60 per HP per


Above 500 units Rs. 6.45 per unit Rs. 65 per HP per


Table 86: Small Industries- Approved Tariff for FY 2015-16

Particulars Energy Charges Fixed Charges Small Industrial Service (LT-5) (Load not exceeding 18.65 kW (25HP)

Upto first 500

units Rs. 6.00 per unit Rs. 65 per HP per month of sanctioned

connected load Above 500 units Rs. 6.45 per unit Rs. 65 per HP per month of sanctioned

connected load

of 246 RERC 552/15, 553/15, 554/15

6.8. Medium Industry (LT-6 and HT-3)

6.8.1. For Medium Industrial LT-6 consumers, Discoms have proposed a hike in the fixed charges from Rs. 70/HP/month of sanctioned connected load to Rs. 75/HP/month of sanctioned connected load. In case of medium industries HT-3 consumers, the Discoms have proposed increase in fixed charges from Rs. 150/ KVA/ month to Rs. 165/ KVA/ month. In case of energy charges, Discoms have proposed for an increase from Rs. 6.25/ unit to Rs. 7.00/ unit in both LT and HT consumer categories respectively.

6.8.2. The existing and proposed tariffs are given in the following table.

Table 87: Existing and Proposed Tariff for Medium Industrial Service (LT-6 and HT-3) for FY 2015-16


Medium Industrial Service (LT-6 and HT-3)

Medium Industrial

Service (LT-6) Rs. 6.25 per unit

Rs. 70 per HP per month of sanctioned

connected load or


month

Medium Industrial

Service (LT-6) Rs. 7.00 per unit


connected load or


month Medium Industrial

Service (HT-3) Rs. 6.25 per unit


month

Medium Industrial

Service (HT-3) Rs. 7.00 per unit


month

6.8.3. The tariff determined by the Commission for this category shall be as under:

Table 88: Medium Industries- Approved Tariff for FY 2015-16 Particulars Energy Charges Fixed Charges

Medium Industrial Service (LT-6 and HT-3)

Medium Industrial

Service (LT-6)

Rs. 7.00 per unit Rs. 75 per HP per month of sanctioned connected load or Rs. 165 per kVA of Billing

Demand per month Medium Industrial

Service (HT-3)

Rs. 7.00 per unit Rs. 165 per kVA of Billing Demand per month

6.9. Bulk Supply for Mixed Load (LT-7and HT-4)

6.9.1. Under Bulk Supply for Mixed Load, Discoms have requested increase in fixed charges from Rs. 70/HP/month of sanctioned connected load to Rs. 75/HP/month of sanctioned connected load for LT-7 consumers. For HT-4 category also, Petitioners have sought an increase in fixed charges from Rs.150/KVA/month to Rs.165/KVA/month. Under both LT and HT category,

of 246 RERC 552/15, 553/15, 554/15

Discoms have proposed an increase from Rs. 6.25/ unit to Rs. 7.00/ unit as given in the table below:

6.9.2. The existing tariff and proposed tariff are given in the following table.

Table 89: Existing and Proposed Tariff for Bulk Supply for Mixed Load Category (LT-7 ad HT-4) for FY 2015-16


Bulk Supply for Mixed Load Category (LT-7 and HT-4)

Bulk Supply for Mixed Load

Service (LT-7)

Rs. 6.25 per unit


connected load or


month


Service (LT-7)

Rs. 7.00 per unit


connected load or


month Bulk Supply for

Mixed Load

Service (HT-4)

Rs. 6.25 per unit Rs. 150 per kVA of Billing Demand per

month


Service (HT-4)


month

6.9.3. The Commission accepts the proposal of increase in Tariff for both HT and LT category at the same level as that of Medium industries as the same is justified.

6.9.4. Accordingly, the tariff determined by the Commission for this category shall be as under:

Table 90: Bulk Supply for Mixed Load Category (LT-7 and HT-4)-Approved Tariff for FY 2015-16

Particulars Energy Charges Fixed Charges Mixed Load Category (LT-7 and HT-4)

Bulk Supply for Mixed Load(LT-7)

Rs. 7.00 per unit Rs. 75per HP per month of sanctioned connected load

or Rs. 165 per kVA of Billing Demand per month

Bulk Supply for Mixed Load(HT-4)

Rs. 7.00 per unit Rs. 165 per kVA of Billing Demand per month

6.10. Large Industries (HT-5)

6.10.1. Discoms have proposed increase in fixed charges from Rs. 170/ KVA/ month to Rs. 185/ KVA/ month. For energy charges, Discoms have proposed to increase from Rs. 6.50/ unit to Rs. 7.30/ unit.

6.10.2. The existing tariff and proposed tariff are given in the following table:

of 246 RERC 552/15, 553/15, 554/15

Table 91: Large Industrial Category (HT-5) - Existing and Proposed Tariff for FY 2015-16 Existing Tariff Proposed Tariff

Particulars Energy Charges Fixed Charges Particulars Energy Charges Fixed Charges Large Industry HT-5

SCL above 150 HP & per or having

Contract per Maximum

Demand above 125 kVA


month

SCL above 150 HP & per or having

Contract per Maximum

Demand above 125 kVA


month

6.10.3. The approved tariff for this category is as under:

Table 92: Large Industries- Approved Tariff for FY 2015-16 Particulars Energy Charges Fixed Charges

Large Industry HT-5 Large Industrial Category (HT-5) Rs. 7.30 per unit Rs. 185 per kVA of Billing

Demand per month

6.11. Online payment charges

6.11.1. Discoms submitted that in the Tariff Order for FY 2014-15 dated 20th February 2015, the Commission had directed the Discoms to provide the facility of online payment via debit/credit card free of charge up to the bill payment of Rs. 5000/-.

6.11.2. The Discoms are incurring transaction charges of approximately 0.75% to 1% on credit card and debit card transactions made by consumers for online payment of electricity bills. In the current scenario, a consumer making an online payment against a bill of Rs. 5000/- leads to the Discom incurring transaction charges of Rs. 38/- to Rs. 50/- per bill. As this cost is on the higher side, the Discoms prayed to the Commission to revise the limit of transaction charges to be borne by the Discom. In case of payments made through credit/debit cards, Discom proposed to bear the transaction charges upto Rs. 10. In case the transaction charges are above Rs. 10, the entire amount shall be borne by the consumer.

Commission’s view 6.11.3. Consumers opposed the current proposal of Discoms stating that in the

present times, use of technology must be promoted as it will allow the timely recovery of revenue to the Discoms and also facilitate the consumer.

6.11.4. It has been observed by the Commission that in its last year order dated 20.02.2015, on the request of Discoms only, the Commission had directed the Discoms to provide the facility of online payment via debit/credit card free of charge up to the bill payment of Rs. 5000/-.

of 246 RERC 552/15, 553/15, 554/15

6.11.5. On the current year proposal of Discoms “In case the transaction charges are above Rs. 10, the entire amount shall be borne by the consumer”, the Discoms have not furnished any factual report, neither have they furnished the quantum of extra burden on Discoms of such additional charges of Rs. 38 to Rs. 50 borne by the Discoms. Therefore, the Commission has not accepted the proposal of Discoms. Discoms may discuss with banks and financial institutions and work out a plan to lessen the burden of these charges on the Discoms.

6.11.6. The Discoms shall consider implementing online meter reading, billing and collection beginning with Industry and Non Domestic categories within next financial year. This may solve the major concerns of Discoms including increasing commercial losses.

6.12. Jaipur Metro Rail Corporation (JMRC)

6.12.1. JVVNL submitted that in the Tariff Order for FY 2014-15 dated 20th February 2015, the Commission had directed JVVNL to look into the matter for making suitable arrangements/adjustments in metering and billing of traction/non traction load in consultation with JMRC. In this regard, a joint meeting of Discom’s officers and Jaipur Metro officials was held on 13th April’15. It was intimated by Jaipur Metro that it is not feasible to segregate traction and non-traction loads by Jaipur Metro for separate metering and billing purposes. The officials of Discom also agreed to this that there is no separate electric network of traction and non-traction load and the separation is not feasible.

6.12.2. Currently, JMRC was provisionally being charged under NDS category which has a higher tariff as compared to HT Industry Tariff.Therefore, JVVNL prayed to the Commission that HT Industry Tariff may be made applicable to the Metro without the 10% rebate as is being provided to the Railways till the traction and non-traction loads of the Metro are identified and separated.

6.12.3. JMRC has also requested that facility of integrated maximum demand may also be extended to them.

Commission’s view

6.12.4. As per the joint meeting of JVVNL and JMRC officials, the segregation of traction and non traction loads is not feasible and after detailed deliberation and discussion, all members of the committee were of the opinion that a single combined tariff may be considered for metro service in

of 246 RERC 552/15, 553/15, 554/15

line with other cities where the metro service is functioning in the country. JMRC had also apprised that its load on traction is approximately 30% and that of non traction is 70%.

6.12.5. Further, JVVNL, in the current petition, also proposed that the HT Industry tariff should be applicable to JMRC without the rebate of 10% allowed on traction load by the Commission. It was also apprised that predominant load of Metro is non traction load which has a higher tariff as compared to HT Large Industry Tariff and proposal of Discoms will put Metro in a preferential position and reduce the burden of JMRC from paying the highest category tariff, i.e., of NDS. JMRC has also requested for a single tariff for traction and non traction loads. Commission observes that in view of the fact that 70% load of Metro is non-traction load, if a lower tariff is applied to total load, JMRC is incentivized. The Commission accordingly accepts the proposal of Discom to bill JMRC at HT large industrial tariff without 10% rebate till the traction and non traction loads of the Metro are identified and separated.

6.12.6. As far as the issue of integrated maximum demand is concerned, the Commission has observed that this facility has been allowed to Railways in respect of Traction Load only and, in view of the fact that segregation of traction and non-traction load is not feasible in the case of Metro, the request for allowing the facility of integrated maximum demand on traction load to JMRC cannot be considered further.

6.12.7. With regard to the proposal of JMRC for allowing blocking of leading power factor load, the Commission is of view that the current provision of power factor has been made keeping in view the overall system requirement and not for a particular consumer. Therefore, the Commission is not inclined to accept the proposal of allowing blocking of leading power factor measurement.

6.12.8. The revised HT Large Industrial Tariff shall be applicable to Metro prospectively with effect from date of applicability of this order.

6.13. Approved tariff for FY 2015-16

6.13.1. In the light of discussions as above, the approved tariff for FY 2015-16 for different categories is appended with this order which indicates existing tariff as well as the approved tariff based on revisions allowed by the Commission.

6.14. Revenue due to tariff revision

6.14.1. Discoms while making the tariff proposal for FY 2015-16 have shown a

of 246 RERC 552/15, 553/15, 554/15

combined deficit of Rs.10,021 Crores and proposed a tariff increase of Rs. 2,993 Crores, leaving a deficit of Rs. 7,029 Crores even after proposed tariff increase.

6.14.2. However, the Commission has reworked out a deficit of Rs. 3383 Crores at existing tariff for FY 2015-16. Even after considering the full tariff increase sought by Discoms, some gap will still remain.

6.14.3. Discoms should factor in the benefits of UDAY Scheme, which may accrue as per an MoU signed with Government of India and Government of Rajasthan, when ARR & Tariff Petitions for the year 2016-17 and thereafter are filed so that the benefit is passed on to the Consumers as envisaged in the scheme. The benefits expected to accrue out of the UDAY Scheme, though may not be quantified now, but, in our view will give a good measure of relief to the consumers in the years to come.

6.14.4. If the State Govt. provides subsidy for any category of consumers in advance in the manner as specified in RERC (Terms & Conditions for Determination of Tariff) Regulations, 2014, the Discoms may apply the subsidised rate to that category.

6.14.5. Discom wise revenue at existing and revised tariff as approved by the Commission are as follows:

Table 93: Jaipur Discom- Revenue at Existing & Revised Tariff for full year as Approved by the Commission for FY 2015-16 (Rs. crore)

Consumer Categories Revenue at Existing Tariff

Revenue which would have accrued at

Revised Tariff Increase

Domestic 2,738 3,044 307 Non-Domestic 1,532 1,714 182 Public Street Light 115 129 14 Agriculture (Metered) 2,528 2,666 138 Agriculture (Flat) 175 185 10 Small Industry 220 245 25 Medium Industry 536 597 61 Large Industry 2,936 3,279 344 Public Water Works (S) 139 155 17 Public Water Works (M) 28 32 3 Public Water Works (L) 191 214 23 Mixed Load 135 151 16 Electric Traction* - - - Total 11,272 12,412 1,139 *Consumption and revenue of Electric traction has been included in the large industry category

of 246 RERC 552/15, 553/15, 554/15

Table 94: Ajmer Discom- Revenue at Existing & Revised Tariff for full year as approved by the Commission for FY 2015-16 (Rs. crore)


Revenue which would have

accrued at Revised Tariff

Increase

Domestic 2,096 2,329 233 Non-Domestic 807 902 95 Public Street Light 57 64 7 Agriculture (Metered) 1,646 1,735 89 Agriculture (Flat) 452 478 26 Small Industry 191 213 22 Medium Industry 570 636 66 Large Industry 1,672 1,870 198 Public Water Works (S) 157 176 19 Public Water Works (M) 28 32 3 Public Water Works (L) 120 134 14 Mixed Load 78 88 9 Electric Traction - - - Total 7,876 8,658 782

Table 95: Jodhpur Discom- Revenue at Existing & Revised Tariff for full year as approved by the Commission for FY 2015-16 (Rs. crore)


Revenue which would have

accrued at Revised Tariff

Increase

Domestic 1,850 2,055 205 Non-Domestic 802 897 95 Public Street Light 98 109 12 Agriculture (Metered) 3,850 4,058 208 Agriculture (Flat) 521 551 30 Small Industry 157 175 18 Medium Industry 440 490 50 Large Industry 982 1,096 113 Public Water Works (S) 149 167 18 Public Water Works (M) 70 79 8 Public Water Works (L) 297 333 36 Mixed Load 235 262 27 Electric Traction - - - Total 9,452 10,272 820

6.15. Cross Subsidy

6.15.1. As per Regulation 89 of RERC (Terms and Conditions for Determination of Tariff) Regulations, 2014, the average cost of supply and realization from a category of consumers shall form the basis of estimating the extent of cross

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subsidy and determination of tariff for that consumer category.

6.15.2. Regulation 89 of RERC (Terms & Condition of Tariff) Regulations, 2014 read with National Tariff Policy makes it evident that average cost of supply has to be the benchmark in assessing cross-subsidy from any consumer category. The National Tariff Policy states that SERC shall notify a road map with a target that tariff are within +/- 20% of average cost of supply. The Commission has also specified in its Tariff Regulations that the Commission shall endeavour to determine the tariff in such a manner that it progressively reflects the average cost of supply and the extent of cross subsidy to any consumer category is within maximum range of +/- 20% of average cost of supply.

6.15.3. The last tariff revision in the year 2015 was just the fourth revision after National Tariff Policy initially came into force. Considering the historical status of huge variation in category wise tariff, bringing the cross subsidy for all categories within the +/- 20% range will be done through successive tariff revisions.

6.15.4. Average cost of supply for the three Discoms as per ARR and sales considered by the Commission earlier in this order is as under:

Table 96: Average Cost of Supply Particular JVVNL AVVNL JdVVNL Rajasthan Net ARR (Rs. In crore) 12,625 9,657 11,520 33,802 Sales (MU) 17,934 12,633 16,799 47,366 COS (Rs./Unit) 7.04 7.64 6.86 7.14

6.15.5. As the FY 2015-16 is already over and the Discoms have not realized any revenue at revised tariff, therefore, cross subsidy for various consumer categories at existing tariff in 2015-16 remained unchanged. However, based on revised tariff contained in this order. The following will be cross subsidy:-

Cross subsidy JVVNL AVVNL JdVVNL Rajasthan Domestic -3.59% -3.88% -1.31% -2.64% Non-Domestic 24.70% 17.77% 32.27% 24.84% Public Street Light 5.15% -0.14% 7.12% 4.11% Agriculture (Metered) -28.69% -33.87% -28.48% -30.34% Agriculture (Flat) -42.32% -39.87% -33.09% -36.91% Small Industry 5.19% -0.93% 10.12% 5.12% Medium Industry 13.55% 3.98% 18.66% 12.34% Large Industry 24.59% 9.25% 35.58% 22.28% Public Water Works (S) 7.50% 4.40% 10.62% 7.15% Public Water Works (M) -5.21% -11.22% -5.26% -6.79% Public Water Works (L) 5.96% -0.97% 9.63% 5.32% Mixed Load 15.11% 1.97% 13.16% 10.30%

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6.15.6. The Discoms have prayed for recovery of uncovered gap through the proposed tariff to be made applicable to the consumers for 2015-16. However, considering that the year 2015-16 has ended, the Commission does not want to order recovery of charges by Discoms as per revised tariff from the date of the tariff petitions, i.e., 28.08.2015. Instead, we order that the revised tariff shall be applied w.e.f. 01.09.2016 and the gap for FY 2015-16 and for further first five months of FY 2016-17 shall be treated as regulatory asset to be passed on during consideration of future petitions. This, in our view, will balance the interest of consumers and the Discoms adequately.

6.15.7. Based on discussion held in foregoing paras, the estimated revenue increase for FY 2015-16, assuming revised tariff remains applicable for the full year, is Rs. 2742 Crore. However, considering that even in FY 2016-17 the revised tariff will remain applicable for only part of the year, the likely increase in revenue for FY 2016-17 will be much lesser than the estimated revenue increase. Even this increase will not be able to meet the revenue deficit likely to occur in FY 2016-17.

6.15.8. This tariff order shall come into force from 1st September, 2016 and remain in force till the next tariff order of the Commission. All existing provisions which are not modified by this order shall continue to be in force. Discoms shall publish salient features of tariff within one week in two daily newspapers in Hindi and one in English having large circulation in their respective areas of supply. Discoms shall revise the existing tariff structure in accordance with this order and publish in Hindi and English a booklet containing all details of tariff and its applicability for the benefit of consumers. It should be made available for sale to general public on a nominal price.

(Raghuvendra Singh) (Vinod Pandya) (Vishvanath Hiremath) Member Member Chairman

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Section 7: Commission Directives and Compliance

7.1. In Appeal No. 16 of 2014 wherein a grievance was made on the non-compliance of the directions issued by Commission, Hon’ble APTEL has directed the State Commission to take action against the Discoms for non-compliance of the directives of the State Commission considering the provisions of Section 24 of the Electricity Act, 2003 and other relevant provisions of law and regulations as the State Commission deems fit and proper.

7.2. In the light of the above order of the Hon’ble APTEL on compliance of directions, we have considered the compliance of directions in letter and spirit by the Discoms. While doing so, the Commission has also taken a note of the views expressed by the Stakeholders on them.

7.3. The directions of the Commission are broadly divided in two parts. Some are general in nature pertaining to filings, Hindi translation, etc. while the others are specific in nature and require execution like segregation of losses, metering, etc. and aim at efficiency improvement of Discoms. Some of these require continuous efforts on the part of Discoms and are to be rolled over the years till the desired results are achieved. In its order dated 20/02/2015, the Commission had given the following directions to the Discoms and Discoms have submitted their replies as follows:

7.4. Commission Directives in ARR order dated 20.02.2015 for FY 2014-15 and Discoms’ reply are as follows:

Sr. No. Para No. Directives

1

2.1 Incomplete and inaccurate formats

To ensure submission of formats (as required by the Regulations framed by the Commission) in conformity with audited accounts of Discoms and reasons to be recorded for leaving any column blank. (2.1.3 of TO)

JVVNL In the Petition for ARR for FY 2015-16 (second year of the control period 2014-15 to 2018-19), the Petitioner has made genuine efforts to provide the information as per the prescribed formats. All the information pertaining to

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the ARR and tariff has been furnished. AVVNL In the Petition for ARR for FY 2015-16 (second year of the control period 2014-15 to 2018-19), the Petitioner has made genuine efforts to provide the information as per the prescribed formats. However, in some places despite the best efforts of the Petitioner, information could not be gathered. Such columns have been left blank and appropriate reason has been mentioned. JdVVNL In the Petition for ARR for FY 2015-16 (second year of the control period 2014-15 to 2018-19), the Petitioner has made genuine efforts to provide the information as per the prescribed formats. However, in some places despite the best efforts of the Petitioner, information could not be gathered. Such columns have been left blank and appropriate reason has been mentioned.

2 2.3 Mismatch in petition and accounts

1 To ensure that there is no mismatch in petition and accounts in future. 2 (2.3.3 of TO)

JVVNL The Petitioner has made sure that there is no mismatch in the figures mentioned in the Petition and those shown in the audited accounts. AVVNL The Petitioner has made sure that there is no mismatch in the figures mentioned in the Petition and those shown in the audited accounts. JdVVNL The Petitioner has made sure that there is no mismatch in the figures mentioned in the Petition and those shown in the audited accounts.

3

2.6 Approved Vs Actual Sales

To indicate the sales and revenue figures at both existing and revised tariff separately in all future petitions. (2.6.3 of TO)

JVVNL Sales and revenue figures, both existing and revised, have been submitted separately. AVVNL Sales and revenue figures, both existing and revised, have been submitted separately. JdVVNL Sales and revenue figures, both existing and revised, have been submitted separately.

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4

2.26 Incomplete forms and information

To ensure submission of complete information in prescribed formats along with the ARR/Tariff petition in future. (2.26 of TO)

JVVNL In the Petition for ARR for FY 2015-16 (second year of the control period 2014-15 to 2018-19), the Petitioner has made genuine efforts to provide the information as per the prescribed formats. All the information pertaining to the ARR & Tariff has been furnished. AVVNL In the Petition for ARR for FY 2015-16 (second year of the control period 2014-15 to 2018-19), the Petitioner has made genuine efforts to provide the information as per the prescribed formats. However, in some places despite the best efforts of the Petitioner, information could not be gathered. Such columns have been left blank and appropriate reason has been mentioned. JdVVNL In the Petition for ARR for FY 2015-16 (second year of the control period 2014-15 to 2018-19), the Petitioner has made genuine efforts to provide the information as per the prescribed formats. However, in some places despite the best efforts of the Petitioner, information could not be gathered. Such columns have been left blank and appropriate reason has been mentioned.

5 2.28. Flat Rate Consumers

To convert urban flat rate agriculture consumers into metered category within two months of the order and submit report within one month of the conversion. (2.28.3 of TO)

AVVNL It is submitted that under Pratapgarh Circle 10 nos. and under Sikar Circle 3 nos. of agriculture flat rate consumers in urban area are still pending for conversion which will be converted by Dec-15. It is also submitted that under Chittorgarh Circle 28 nos. of agriculture flat rate consumers in urban area are lying disconnected and will be reconnected only by installing meters.

6 2.29 Hindi petition

To file the Hindi version of petition along with English version in time. (2.29.3 of TO).

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JVVNL The Hindi version of the petition has also been submitted along with the English version. AVVNL The Hindi version of the petition has also been submitted along with the English version. JdVVNL The Hindi version of the petition has also been submitted along with the English version.

7

2.30 Assessment of T&D and AT&C Losses

To come out with an action plan along with methodology and time frame for implementation of energy audit and segregation of technical and commercial losses within a period of (2) months from the date of the order. (2.30.3.1 of TO) To report losses of urban areas/towns where RAPDRP program has been implemented. (2.30.3.3 of TO) To ensure no new feeders/substations are sanctioned/ constructed without proper metering in place and top priority should be given to completion of metering of existing substations and to monitor and report losses on the feeders/substations. (2.30.3.4 of TO)

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JVVNL Discom has already made an action plan for energy audit by assigning this work exclusively to Meter Protection Wing of the Discom to provide 100% meters on 11 kV feeders along with boundary and cross meters and for validation of energy audit figures on concurrent basis from a third agency. This work shall be completed by 31st Dec 2015. The figures of losses of the urban areas /towns where RAPDRP program is being implemented has been furnished. While sanctioning the proposal of new 33/11 kV sub-stations, it is always ensured that a provision of metering of feeders/substations is kept. New feeders are being constructed with proper metering. The work of metering of pending feeders/substation has already been taken up on top priority and is likely to be completed by Dec 2015. AVVNL Discom has already made an action plan in this regard by entrusting M&P wing of the Discom with the work of implementation of energy audit by providing 100% metering on 11 KV feeders along with boundary meters. 11 KV feeder metering & energy audit It is submitted that so far meters on 6966 feeders have been provided out of 7408 feeders with dedicated 11 KV CTPT set with HTTVM for feeder metering. Discom targets to get the metering done on remaining feeders by Dec-15. Energy audit on 2634 nos. 11 KV feeders has been started and targets for energy audit of 100% feeders is Dec-15. The figures/details of losses of 29 towns covered under RAPDRP have been furnished. While sanctioning the proposal of new 33/11 kV sub-stations, it is always ensured that provision of metering of feeders/substations is kept. New feeders are being constructed with proper metering. The work of metering of pending feeders/substation has already been taken up on top priority under substation improvement works and is likely to be completed by end of this year.

JdVVNL

Discom has already made an action plan in this regard by entrusting M&P wing of the Discom with the work of implementation of energy audit by providing 100% metering on 11 KV feeders along with boundary meters. 11 KV feeder metering & energy audit

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It is submitted that so far meters on 9048 feeders have been provided out of 9164 rural and urban feeders with dedicated 11 KV CTPT set with HTTVM for feeder metering. Discom targets to get the metering done on remaining feeders by March-2016. JdVVNL has submitted the required action plan along with current progress in the matter of feeder metering and segregation of feeders. The consumer indexing on the basis of 11 KV feeder code has also been started and shall be completed soon after which feeder wise energy audit will be started. JdVVNL has submitted the losses of 56 towns covered under RAPDRP. While sanctioning the proposal of new 33/11 kV sub-stations, it is always ensured that a provision of metering of feeders/substations is kept. New feeders are being constructed with proper metering. The work of metering of pending feeders/substations has already been taken up on top priority and is likely to be completed in the next three months.

8

2.33 Defective meters and transformer

To ensure first bill is issued on time and no connection is energised without installing a correct meter. Action to be taken against defaulting officer if the meter is faulty from day one and not replaced within two months of detection as specified at regulation 3.2 of RERC (Standards of Performance for Distribution Licensees) Regulation, 2014. (2.33.3.2 of TO) To maintain history sheet of all transformers in order to improve their maintenance. (2.33.3.3 of TO) To develop the mechanism for carrying out scheduled maintenance of power as well as distribution transformers. (2.33.3.4 of TO) To arrange regular maintenance of 33 KV, 11KV and LT lines. (2.33.3.5 of TO) To check the load on the transformers for overloading as well as unbalanced loads and unbalanced loads should be checked on transformers supplying single-phase loads. (2.33.3.6 of TO) To implement the scheme of providing protection schemes and

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circuit breakers on power transformers and HT feeders. (2.33.3.7 of TO)

JVVNL Strict monitoring is being done to ensure issue of first bill on time. Action against defaulting officers is being taken. All the records and details pertaining to power transformers are being maintained and updated on a half yearly basis by M&P Wing of the Discom. M&P officers have been directed to carry out periodic testing/checking of power transformers to ensure proper maintenance. The reconditioning of single & three phase distribution transformer is also being taken up under feeder improvement programme. Besides this, earthing of transformer; top up of oil, etc. is also being carried out under feeder improvement programme. The Discom carries out routine maintenance of the 33 KV, 11 KV and LT lines to ensure the smooth and efficient working of the system. Load on transformers are being checked for over loading/unbalancing and necessary action is being taken to rectify. 11 KV VCB/kiosks are being installed on LV side of power transformers and on each out going11 KV feeder to provide adequate protection. AVVNL Strict monitoring is being done to ensure issue of first bill on time. For effective monitoring the status, in respect of issuance of first bill, is collected every month from the field and action against defaulting officers is also proposed to be taken. The progress of issue of first bill to consumers during FY 15-16 is has been submitted. All new transformers are purchased strictly as per approved specification. Pre-dispatch sample testing is carried out in factory and after receipt from stores. For ensuring proper maintenance & protection of transformers, order 347 dt. 20.08.2009 has already been issued vide which protection wing under control of meters & protection has been created for carrying out all

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activities pertaining to maintenance & protection of transformers & substation along with maintaining all records of routine testing , preventive maintenance, etc. Dedicated Feeder Managers (M&P) along with staff have been posted for this. Maintenance of distribution transformers is regularly being carried out by Discom for ensuring uninterrupted supply to consumers. Also under Substation Improvement Programme (SIP), the following works are being taken to strengthen the existing net-work covered with objective to provide quality supply to consumers-

1. Replacement of non operative roster switches 2. Installation of new roster switches 3. Repair/replacement of non operative circuit breakers 4. Installation of new circuit breakers 5. Replacement of non functioning feeder meters. 6. Installation of new feeder meters 7. Improvement of earthing at 33 KV substation/power transformers, etc.

The updated progress of SIP has been submitted. Submitted that the petitioner is regularly carrying out maintenance works of all lines. To provide more reliable and un interrupted supply to the Consumers, a special comprehensive programme named Feeder Maintenance Programme has been launched under which following works are being carried out-

1. Tightening of loose wires 2. Straightening of tilted poles 3. Insertion of pole in long span for providing adequate ground

clearance 4. Reconditioning of distribution transformer single phase 5. Reconditioning of distribution transformer three phase 6. Replacement of obsolete AB cables 7. Capacity augmentation of single phase DTs 8. Earthing of single phase DTs 9. Providing three phase systems in villages near to 33/11 KV S/s 10. Tightening of loose AB cable 11. Providing M-seal / repairing of unsealed cable joints. 12. Providing insulated connectors 13. Replacement of defective meters 14. Transformer reading platform, etc.

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The updated progress of FIP has been submitted.

The works of drawing neutral wire up to 33/11KV GSS in single phase loads is covered under GPVVY with the objective of safety of 1 phase system & power transformer. As submitted above the M&P wing has already taken up study of identifying 33 KV substations where phase wise loading is not balanced and carried out work for balancing the load.

The petitioner is committed to provide circuit breakers on all 11 KV incomers and outgoing feeders for feeder and transformer protection. The status as on 31.10.2015 is as follows:- Total 11 KV incoming feeders/power transformers- 2229 Nos., VCBs have been installed on 2229 Nos. Total 11 KV outgoing feeders -7408 Nos. among that VCBs have been installed on -7186 Nos. VCBs on remaining outgoing feeders will be installed by the end of this year. JdVVNL Strict monitoring is being done to ensure issue of first bill on time. Action against defaulting officers is being taken. All new transformers are purchased strictly as per approved specification. Pre-dispatch sample testing is carried out in factory and after receipt from stores. The work of reconditioning of transformers has been taken in feeder maintenance programme to reduce the failure. M&P officers have been directed to carry out periodic testing/checking of power transformers to ensure proper maintenance. A special feeder maintenance programme, has been started to carry out regular maintenance of lines and to reduce the fault on these lines.

Load on transformers are being checked for over loading/unbalancing and necessary action is being taken to rectify.

11 KV VCBs are being installed on incomer of power transformer and on each 11 KV feeder to provide adequate protection.

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9 2.34 Theft of Electricity

To strengthen the vigilance wing and take up frequent checking of theft prone areas. To take appropriate steps to improve revenue collection in relation to revenue assessed in cases of theft. To furnish the information regarding number of checking, theft detected, amount assessed, amount realised, no. of complaints/FIR lodged, arrest made and persons convicted for the last three year. (2.34.3 of TO)

JVVNL A separate Vigilance Wing has been created in Discom for vig. checking. Vigilance & O&M officers are regularly carrying out checkings. All concerned officers are directed to have logical conclusion of vig. checking report at the earliest to improve revenue collection. Due to the constant endeavour of the Discom in the field to curb and control the activities of theft and other misdoing, there has been a major increase in the number of such activities being caught and reported. Also there is a significant increase in the number of FIRs lodged. The number of checkings and number of thefts detected have gone up from 30,957 and 24,218 up to September’14 to 56,024 and 40,484 respectively in September’15. In case of the amount assessed and realized, the figures for September’14 were Rs. 3,724 lac and Rs. 999 lac respectively. In the current year upto September’15 the same has increased to Rs. 5,905 lac and Rs. 2,263 lac respectively. Also, there is a drastic increase in the number of FIRs lodged. Upto September’14, there were 2,276 number of FIRs lodged. In the current year as on September’15, this stands it at 5,705. The efforts put in by the Discom in strengthening the vigilance activities has lead to a significant increase in revenue realized from vigilance, compared to the previous year (70% y-o-y increase in FY 15). Information regarding No. of checkings, theft detected, amount assessed, amount realized and no. of FIRs lodged in the last three years is submitted. AVVNL

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A separate Vigilance Wing is created in Discoms for vigilance checking. Vigilance & O&M officers are regularly carrying out checkings. All concerned officers are directed to have logical conclusion of vigilance checking report at the earliest to improve revenue collection. Information regarding No. of checking, theft detected, amount assessed, amount realized and no. of FIRs lodged in the last three years has already been submitted. The updated status of vigilance checking up till Oct-15 has been submitted. JdVVNL A separate Vigilance Wing is created in Discoms for vig. checking. Vigilance & O&M officers are regularly carrying out checkings. All concerned officers are directed to have logical conclusion of vig. Checking report at the earliest to improve revenue collection. Information regarding No. of checkings, theft detected, amount assessed, amount realized and no. of FIRs lodged in the last three years is submitted.

10 2.35 Public Street Light

To carry out vigilance campaign for finding unmetered points in Public Street Light category and assessment to be made in accordance with provisions of Supply Code Regulations. (2.35.3 of TO).

JVVNL The field officers have been directed to carry out vigilance campaign for checking direct light points of public street light and to make assessment accordingly. This issue is also being incorporated under vigilance campaign drive. AVVNL The field officers have been directed to carry out vigilance campaign for checking direct light points of public street light and to make assessment accordingly. JdVVNL The field officers have been directed to carry out vigilance campaign for checking direct light points of public street light and to make assessment accordingly.

11

2.36 Voltage Wise cost of Supply

To furnish voltage wise cost of supply in next tariff petition. (2.36.3 of TO)

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JVVNL The Discom is making its best efforts to calculate the voltage wise losses for 33kV and 11KV for which action plan has already been finalized. In the first phase, work of energy audit has been assigned to Meter Protection wing of the Discom to provide 100% meters on 11 kV feeders along with boundary and cross meters and for validation of energy audit figures on concurrent basis from a third agency. The Voltage wise cost of supply has been calculated as per the order of Hon’ble APTEL in Appeal no. 102 of 2010. Interpretation of the same methodology has been provided in another order of Hon’ble APTEL in Appeal no. 152 of 2013 according to which the Discom has worked out and submitted the Voltage wise cost of supply. AVVNL The Voltage wise cost of supply has been calculated as per the orders of Hon’ble APTEL in Appeal no. 102 of 2010. Interpretation of the same methodology has been provided in another order of Hon’ble APTEL in Appeal no. 152 of 2013 according to which the Discom has worked out the Voltage wise cost of supply and submitted along with the reply to data gaps. JdVVNL The Petitioner would like to submit that to calculate the voltage wise cost of supply, it needs to carry out field studies with representative feeders of the various consumer mixes prevailing in the distribution system. However, it also has to be highlighted that carrying out field studies at representative feeders is a time consuming activity. In order to conduct such studies, the first step is to identify data requirement and finalization of representative sample of assets on each voltage level for monitoring and collection of such data. The Petitioner has already begun the process of determination of cost of supply by categorizing the data requirement and sample assets to be monitored.

12 2.42 Depreciation

To furnish factual report on the work of preparation of fixed asset register and a cut-off date by which the work would be complete. (2.42.3.2 of TO)

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JVVNL The Discom has already assigned the work regarding preparation of fixed assets register and the work is expected to be completed by year end. AVVNL It is submitted that the petitioner is maintaining block wise Fixed Assets Registers. The Block wise Fixed Assets Registers of all Circles except Banswara circle upto the financial year 2011-12 have been prepared. The FAR (Fixed assets register) of Banswara circle has also been prepared up to financial year 2007-08. The petitioner is applying in-house vigorous efforts to complete the Fixed Assets Register up to the financial year 2014-15 as early as possible. JdVVNL It is also submitted that the voltage wise allocation of fixed assets and the segregation of technical losses at different voltage levels is required for the determination of voltage wise cost of supply. In this regard, the Petitioner has already filed a petition with the Hon’ble Commission appealing for a change in regulations highlighting the issues being faced while trying to maintain a voltage wise fixed assets register. During the last several years, not only in Rajasthan but in other states also, the concept of Gross Asset Register at each voltage level could not be implemented. This is due to the dichotomy between the working of the Chartered Accountants and the authorities in the power sector. In the power sector, voltage-wise figures are quite relevant but according to the Accounting Standards and Company Law requirements, the audited accounts deal with the total assets of a company and not the assets at each voltage level. Since nowhere in the country voltage-wise figures are certified by the auditors, therefore, necessarily the Discoms have to resort to certain assumptions while indicating voltage-wise assets. Hypothetically, even if the Discoms were to bifurcate the voltage-wise figures, the auditors cannot certify those figures. Hence, when audited figures are required, Discoms have to follow the norms and methodology prescribed for the maintenance of accounts as per the Companies Act.

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13

2.63 Miscellaneous

To run consumer awareness/consumer education campaigns using the allowed additional amount of Rs. 50 lakh per Discom. (2.63.3.2 of TO) To develop a system to meet standards of performance as laid down in RERC Regulations, 2014. (2.63.3.6 of TO) To ensure publication of manual for handling consumer complaints at an early date and establish call centres as stipulated in the Regulations. (2.63.3.7 of TO) DSM cell of Discoms may promote drip irrigation system and use of energy efficient pump sets among farmers. DSM cell may coordinate with Agriculture University and Agriculture Department to set up demonstration units of drip irrigation and conduct consumer education program for agriculture consumers for showing benefit of use of energy efficient pump sets and drip irrigation. The Discoms are also directed to analyse the benefits of carrying out DSM program for agriculture consumers and review the present incentive being given to agriculture consumers for use of energy efficient pump sets/drip irrigation system and file proposal for cost reflective incentive, if need be. Utilities may prepare a scheme for giving suitable incentive to staff & officers every year for achievement in loss reductions. To ensure availability of proper facilities/basic amenities for consumers at Discom offices/bill collection centres. (2.63.3.8 of TO)

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JVVNL The Discom is preparing various schemes regarding consumer awareness and consumer education. Discom is also spreading consumer awareness through electronic media, video conferencing, SMS, Choupals, publicity in Newspapers, etc. Besides this, a Bijli Jan Jagrukti Abhiyan is also being carried out in which MLAs, Sarpanchs, Pradhans also participate and consumers are educated through slides about the benefit of energy conservation, prevention of electrical accidents and burden of electricity thefts, etc. Further, to motivate and spread out these activities in public at large, the help of school children is also taken by organising drawing and slogan competitions as well as road shows/rallies. One such Bijli Jan Jagrukta Abhiyan has already been conducted in Kanota Sub division in the month of August’ 2015 and the results found are very encouraging. Manual regarding SOP regulations have been published. All the field officers have been directed to ensure compliance in line with the standards prescribed in SOP regulation. The DPR has been prepared by M/S EESL for the use of energy efficient pump sets among agriculture consumers. Two successful pilot projects have been undertaken in Agricultural Demand Side Management which have proved that investment in energy efficient agricultural pump sets can payback in a short time. Taking the average energy savings outcome of the two pilots, a 30% reduction in energy consumption and subsidy is possible by replacing all existing pumps with star rated energy efficient pump sets. Similar demand side management plans have also been outlined for other categories including municipality, commercial, street lights, etc.

The scheme for providing suitable incentives to staff and officers for achievement in loss reduction has been prepared by the Discom. Appropriate facilities/basic amenities for consumers such as sitting room at Discom offices & tin shed at bill collection centres have been provided.

AVVNL The Domestic Efficient Lighting Program (DELP) for distribution of LED bulbs to the consumers of Discom under DSM program through an Energy Service Company (ESCO), M/s Energy Efficiency Services Ltd. (EESL), has been

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started. Also, the field officers have been directed vide letter No. 506 dated 17.07.2015 to follow the guidelines issued by the Hon’ble Commission regarding utilization of additional amount so allowed for consumer awareness/consumer education campaigns. For meeting the standards prescribed in SOP Regulations, orders have been issued to the field officers vide Comml AJ-562 dated 06.01.2015 and 563 dated 15.01.2015 for strict compliance of the SOP Regulations failing which the compensation payable to the aggrieved consumer is to be given for which defaulting officer will be identified and held responsible. Moreover, time and again the officers have been directed for compliance of the provisions of SOP Regulations. Manual as per provisions of SOP Regulations has been published in Hindi and English both. The manual contains the details of standards to be met, details of call centers, etc. All the field officers have been directed to ensure compliance of the provisions of SOP Regulations. In order to enable Discom to use DSM cell as a resource in their overall planning, a MOU has been signed with Bureau of Energy Efficiency (BEE) to take up DSM as a mainstream activity. Under this, BEE has further signed an MOU with Energy Efficiency Services Ltd. (EESL) for supporting Discom in developing approach and methodology for Load Survey and Research, Load Strategies and development of DSM action plan. This plan also includes the approach to alter load profile and load curve so as to help Discom in reducing its peak power purchase cost for which educating consumers to adopt energy saving/efficient equipments and technologies is an inherent part. This work is under progress. Moreover, in the Vidyut Chaupals held on every Tuesday at 33kV substation of rural subdivisions, the farmers are advised for adopting the drip irrigation system and energy efficient pumpsets with specific mention of the advantages of using them and incentives allowed to them in the tariff also @ 10 paisa per unit in the “Energy Charges” for using energy efficient pumpsets (3 star and above) as well as sprinkler sets. It is submitted that the basic amenities for the consumers are in existence in almost entire area of Discom barring few (approximate 23 subdivisions) for which all efforts will be made to provide the same by end of this year positively.

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JdVVNL The Domestic Efficient Lighting Program (DELP) for distribution of LED bulbs to the consumers of Discom under DSM program through an Energy Service Company (ESCO), M/s Energy Efficiency Services Ltd. (EESL), has been started. Also, the field officers have been directed vide letter No. 506 dated 17.07.2015 to follow the guidelines issued by the Hon’ble Commission regarding utilization of additional amount so allowed for consumer awareness/consumer education campaigns.

Manual regarding SOP regulations has been published. All the field officers have been directed to ensure compliance in line with the standards prescribed in SOP regulations.

The DPR is being prepared by M/S EESL for the use of energy efficient pump sets among Agriculture consumers.

All efforts are being made to provide proper facilities for consumers at offices of Discoms.

14 2.69 Jaipur Metro Rail Corporation

To look into the matter for making suitable arrangements/adjustments in metering and billing of traction/non traction load in consultation with JMRC within one month from date of order and to submit its report to commission within three months of the order. (2.69.3.2 of TO) To examine the technical and financial implications of allowing such facility to Railways and furnish the reason why such facility should not be extended to JMRC. (2.69.3.3 of TO)

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JVVNL In compliance to the directive, a joint meeting of Discom officers and Jaipur Metro officials was held on 13/4/15. Minutes of the meeting are enclosed with the Petition. It was intimated by the Jaipur Metro members that it is not feasible to segregate traction and non-traction load by Jaipur Metro for separate metering and billing purposes. The concerned Executive Engineer of the Discom also apprised that there is no separate electric network of traction and non-traction load and the separation is not feasible. Committee was of the opinion that a single combined tariff may be considered for Jaipur Metro services in line with other Metro services of the country. AVVNL There is no traction connection in Ajmer Discom area at present. JdVVNL Applicable to Jaipur Discom only.

15

4.13 Proposed investment plan, analysis and decisions of the Commission

To carry out prudence check on five to ten schemes/works under each head of plan being carried out during the year and furnish a report indicating cost benefit analysis and effectiveness of the investment made to the Commission by 30th June 2015. (4.13 of TO)

JVVNL It is submitted that at present only those proposals of new 33/11 kV substations are considered for sanction having benefit to cost ratio of 12 or above in rural areas. Also, vide order no. D-232 dated 27/1/15 it has been ordered for checking of quality of ongoing works on random basis. Copy of the mentioned order is submitted. AVVNL It is submitted that at present only those proposals of new 33/11 kV substations are considered for sanction having benefit to cost ratio of 12 or above. Also, vide letter no. 6608 dated 20.11.2015, 5 circles SEs have been again reminded and directed for checking of quality of ongoing 10 works on random basis and to furnish report. Copy of reminder is submitted. Upon receipt of the reports from them, the same will be submitted for kind consideration of the Hon’ble Commission. JdVVNL It is submitted that at present only those proposals of new 33/11 kV

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substations are considered for sanction having benefit to cost ratio of 12 or above. It has been ordered for checking of quality of ongoing works on random basis. Copy of the mentioned order is submitted.

16 6.17 Incentive on prompt payment

To ensure timely delivery of bills and aggressively promote registration of consumers for getting SMS on mobile phone regarding issue of bills. (6.17.3 of TO).

JVVNL All efforts are being made by the Discom to ensure the timely delivery of the bills to the consumers. Timely billing has already started in the Discom and the same (monthly bill) is also available on the Discom’s website and SMS alert has also been activated to those consumers who have registered their account details on the website. AVVNL All efforts are being made by the Discom to ensure the timely delivery of the bills to the consumers. As of now, LIP category consumer bills are hosted on the web portal of the Discom with SMS alerts also being sent to them. JdVVNL All efforts are being made by the Discom to ensure the timely delivery of the bills to the consumers.

17 6.19 Change in applicability for Temporary supply

To send a suitable proposal for amendment in supply code. (6.19.2 of TO)

JVVNL The application for proposal for amendment in Supply Code has been submitted to the Hon’ble Commission by the Discom on dt.24.04.15. AVVNL The petition for amendment in Supply Code Regulations has been submitted to the Hon’ble Commission by the Discom on dt.24.04.15. JdVVNL The application for proposal for amendment in Supply Code has been submitted to the Hon’ble Commission by the Discom on dt.24.04.15.

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After consideration of the submissions made by Discoms on the compliance of directions, the Commission views on each of the compliances are as follows:

Commission View: Re: Proper Filing of the Petition, etc. (Directions 1 to 4 and 6)

7.5. So far as the direction relating to filing of the petition is concerned, the Commission has ensured due compliance of the same. Initially, Discoms had not filed petitions fully in accordance with the tariff regulations. Therefore, before proceeding to consider the petitions on merits Commission required the Discoms to furnish the necessary information/data. Accordingly the required data have been furnished. This issue has also been considered in detail in Section1 and, therefore, there is no need to repeat the same.

7.6. Discoms have filed revenue figures both at existing and revised tariff, filed Hindi version of the petition and have complied with the directions.

7.7. However, Commission observes that the Discoms shall, while filing petitions for future years, provide all requisite information in complete form so as not to give room for any complaint in this regard and to enable the Commission to take expeditious decision on the petition.

Re: Flat Rate Consumers (Direction 5)

7.8. While passing its order dated 20/2/2015, the Commission had directed all Discoms to convert urban flat rate agriculture consumers to metered category within a period of 2 months and submit a report within one month of the conversion. The report of compliance has not been furnished till now. It would be observed that conversion of flat rate consumers to metered category is in the interest of Discoms and would have led to reduction of commercial losses. Since Discoms have failed to take action and report the same, the Commission decides to impose a penalty of Rs. 5.00 lakh from ARR of each Discom and again directs to provide the report before they file their next petition otherwise entire energy consumed by these consumers may be disallowed in the ARR.

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Re: Assessment of T&D and AT&C Losses (Direction 7)

7.9. Discoms have submitted the action plan for energy audit and segregation of technical and commercial losses and complied with the directions of the Commission.

7.10. Discoms have also submitted the losses of towns covered under RAPDRP and have complied with the directions.

7.11. Jaipur, Ajmer & Jodhpur Discoms have respectively submitted data of T&D losses of 27, 29 & 56 towns/sub-divisions. It has been observed that losses in some areas are quite high.

7.12. In Jaipur Discom out of 27 towns, only 3 towns have losses below 10%, losses of 2 towns were in the range of 10% to 15 % and losses of balance 23 towns are more than 15%.

7.13. In Ajmer Discom out of 29 towns, only 8 towns have losses below 10%, losses of 9 towns were in the range of 10% to 15 % and losses of balance 12 towns are more than 15%.

7.14. In Jodhpur Discom out of 56 sub-divisions, losses of 9 sub-divisions were in the range of 10% to 15% and losses of 27 sub-divisions are more than 15%. One sub-division reported negative losses which indicate some error in collection of data.

7.15. The Discoms in UDAY Scheme have been targeted to achieve the loss level of 15%. The Discoms may look into the data of losses of Towns/Sub-Divisions furnished to the Commission and analyse the reasons wherever losses are more than 15% and take effective measures to reduce the losses to at least 15%. The Discoms should furnish a detailed report in this regard to the Commission on action taken.

7.16. Regarding directions of the Commission to ensure that no new feeders/substations are sanctioned/constructed without proper metering in place and that top priority should be given to completion of metering of existing substations and to monitor and report losses on the feeders/substations, Discoms have submitted compliance that provision of metering of feeders/substations is being kept. New feeders are being constructed with proper metering. The work of metering of pending feeders/substation has already been taken up on top priority and substantial

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progress has been achieved.

7.17. Under “UDAY Scheme” being implemented by the Discoms, they have undertaken to include the milestones and targets for implementation of energy audit as discussed later in this section.

7.18. Section 4 of the Rajasthan State Electricity Distribution Management Responsibility Act, 2016 which came into force on 15th June 2016 , requires the State Distribution Licensees to prepare, with the approval of the State Commission, a time bound road map for aggregate technical and commercial loss reduction within six months and the State Distribution Licensees to undertake energy accounting and auditing of all 33 KV feeders and 11 KV feeders along with consumer indexing and time bound metering of each category of consumers and in doing so the Distribution Licensee is to consider latest developments in metering technologies. Distribution Transformer level energy auditing will be carried out in Restructured Accelerated Power Development and Reforms Programme towns within two years. It also provides that the road map in relation to energy accounting and auditing and time bound metering of all consumers shall be prepared within six months and approval for the same shall be sought from the State Commission. The consumer indexing shall be completed within one year from the date of coming into force of the said Act.

Re: Defective Meters and Transformers (Direction 8)

7.19. Discoms have submitted compliance of direction regarding issue of first bill on time stating that strict monitoring is being done and action against defaulting officers is being taken. Discoms have also made submission on maintenance of transformers and lines and checking of the load on the transformers and of providing protection schemes and circuit breakers on power transformers and HT feeders. However, the Discoms have not made any submission regarding maintenance of History Sheet.

7.20. The Commission feels that it is for the management of Discoms to look into factors affecting day to day operations of the Discoms. The Commission has only to sensitize the management of the Discoms towards issues raised by Stakeholders regarding maintenance and hope that Discom management will look into this and make full use of R&M expenses and capital investment being allowed by the Commission.

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Re: Theft of Electricity (Direction 9)

7.21. Discoms have submitted that separate vigilance wing is created in Discoms for vigilance checking. Vigilance & O&M officers are regularly carrying out checking. All concerned officers are directed to take logical conclusion of vigilance checking report to improve revenue collection.

7.22. Discoms have also complied with the direction of the Commission regarding furnishing of the requisite information sought by the Commission. Curbing of theft is also a major action point in UDAY Scheme as discussed later in this section.

7.23. Detection of theft of electricity and getting the culprits punished in accordance with law needs no emphasis. Mere raising of back bills will not be enough for preventing the thefts. In appropriate cases, the Discoms shall pursue penal actions initiated both against the consumers and others who conspire. Discoms may also initiate penal action against the employees and officers, if they are found to be conspiring with the person making the theft. It is well know that prevention is always better than cure. Discoms instead of going in search of thieves may consider such initiative which will reduce the scope of theft by regular checking of theft prone installations at such intervals as has been found necessary in each case and also by taking adequate technical corrections, such as installation of tamper proof meters, etc.

Re: Public Street Light points (Direction 10)

7.24. Discoms have complied with the directions and directed their field officers to carry out vigilance campaign for checking direct street light points. It is reiterated that the Commission does not want to indulge in micromanagement of Discoms but wishes to sensitize the Discoms towards field conditions and suggestions for efficiency improvements received through Stakeholders.

Re: Voltage Wise Cost of Supply (Direction 11)

7.25. It has been observed by the Commission that with the current tariff petition,

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the Discoms have filed the voltage wise cost of supply in line with directions of Hon’ble APTEL. Further, with the feeder metering, DT metering and segregation of feeders and energy audit as per the MOU entered under UDAY scheme, the Discoms shall also be able to compute the voltage wise cost of supply with more accuracy in future. In case they need assistance of any experts, they may engage such experts and determine voltage wise cost of supply by the next tariff filing. Re: Fixed Asset Register (Direction 12)

7.26. It is submitted by the JVVNL & AVVNL that they are in the process of preparation of fixed assets register.

Jodhpur Discom has referred that Companies Act does not permit them to maintain voltage wise asset register and when audited figures are required, Discoms have to follow the norms and methodology prescribed for the maintenance of accounts in the Companies Act. JdVVNL has also referred to dichotomy between the working of the Chartered Accountants and the authorities in the power sector. In the Commission’s view, the response of JdVVNL is totally uncalled for and vague. JdVVNL has responded as if it is already having a fixed asset register without voltage wise bifurcation. The Commission at this juncture would like to bring the following provision of the Companies Act, 2013 to the notice of JdVVNL: (4) The provisions of this Act shall apply to—

(a) companies incorporated under this Act or under any previous company law;

(b) insurance companies, except in so far as the said provisions are inconsistent with the provisions of the Insurance Act, 1938 or the Insurance Regulatory and Development Authority Act, 1999;

(c) banking companies, except in so far as the said provisions are inconsistent with the provisions of the Banking Regulation Act, 1949;

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(d) companies engaged in the generation or supply of electricity, except in so far as the said provisions are inconsistent with the provisions of the Electricity Act, 2003;

129. (1) The financial statements shall give a true and fair view of the state of affairs of the company or companies, comply with the accounting standards notified under section 133 and shall be in the form or forms as may be provided for different class or classes of companies in Schedule III: Provided that the items contained in such financial statements shall be in accordance with the accounting standards: Provided further that nothing contained in this sub-section shall apply to any insurance or banking company or any company engaged in the generation or supply of electricity, or to any other class of company for which a form of financial statement has been specified in or under the Act governing such class of company:

7.27. From the above it may be observed that there is no legal impediment to comply with the direction of the Commission. In the Commission’s view it may be difficult for Discoms to find out the old data but not impossible. Therefore Discom may prepare the asset registers taking into account the available data. For the future, petitioners shall maintain the asset register so that the difficulty now faced by them for prior period is not faced by them again. All properties of Discoms should also be accounted for and secured as these are public properties and need to be protected and will be of use for future requirements of the Discoms.

7.28. As per section 7(2) of the recently enacted “Rajasthan State Electricity Distribution Management Responsibility Act, 2016” the State Government shall ensure that the Distribution Licensees complete physical verification and prepare fixed assets register as per accounting standards prescribed under the Companies Act, 2013 within two years.

Re: Consumer Education Campaign

Standards of performance, publication of manual for handling consumer complaints, scheme for giving suitable incentive, benefits of carrying DSM

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program for agriculture consumers, availability of proper facilities/basic amenities for consumers at Discoms offices/ bill collection centres.

(Direction 13)

7.29. It is submitted that Discoms have published the manuals and issued necessary directions to field officers for ensuring compliance in line with the standards prescribed in SOP regulation. Discoms have also furnished the compliance reports on other issues including DSM and facilities for consumers.

7.30. It is noted that the Discoms have initiated domestic efficient lighting programme. This has also been approved by the Commission. The Discoms shall take this forward as this programme results in saving of precious electricity. One of the Stakeholders has suggested that consumers who desire to have more than 3 bulbs may also be allowed to pay in instalments. Commission observes that this request may be examined.

7.31. Commission desires that Government of Rajasthan may examine putting only LED bulbs and tubes in all Government offices of the state as LED lights use less power as compared to conventional lights and a substantial saving of energy as well as cost may be achieved by using LED lights.

7.32. The Discom may also consider to take up the project for replacement of existing conventional street lights with all high efficiency LED street lights through local bodies/Panchayats where the street light can be installed by service provider with no capital cost to local bodies, and payments to service provider may be made through savings accrued.

7.33. Discoms shall make arrangements to inform the consumer about the availability of energy saving pumps, fans and air conditioners, so that consumer may adopt them considering the benefit they may derive from them in the form of savings in electricity charges. Discoms should also consider to extend similar schemes to consumers of other categories.

7.34. The DSM measures proposed under the UDAY Scheme should also be pursued by educating agriculture consumers about the benefit of using energy efficient pumps, pipes and adopting sprinkler/ drip irrigation. This makes more sense in the context of State of Rajasthan where water is a scare resource. The savings through introduction of DSM in agriculture sector is vast and will lead to savings for farmers by way of reduction in bills, for Discom by way of reduction in losses and cost and for the Government by

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way of reduction in subsidy. Energy saved on account of agriculture DSM may be sold to other category consumers with high tariff realisation which will also improve the revenue of the Discoms. For agriculture DSM, the Discoms may also consider to approach the State Government to fund the DSM program over a period to the extent of likely reduction in subsidy. UDAY Scheme also contains provisions for an Employee Financial Incentive Scheme.

7.35. The Commission had allowed Rs. 50 lakh per Discom to enable Discom to conduct consumer awareness campaign periodically and institutionalize a mechanism for having a dialogue with the consumers for educating them and addressing common problems. Stakeholders welcomed the steps and requested the Commission to continue the same. The Commission has considered such expenses for FY 2015-16 also. Stakeholders also pointed that when they visit a subdivision there is no one to guide and facilitate them. Discoms may consider to designate one officer/ employee as “consumer friend” to guide/ facilitate the consumers. Further, Discoms shall not hesitate to provide seating arrangements, etc. as these are the minimum courtesies to be provided to the consumers.

Re: Tariff for Jaipur Metro (Direction-14)

7.36. Discoms have held a joint meeting with Metro officials as per directions of the Commission and have also made proposals in the tariff petition. As such, the direction has been complied with.

Proposed Investment Plan and Analysis (Direction-15)

7.37. Discoms have submitted that at present only those proposals of new 33/11 kV substations are considered for sanction having benefit to cost ratio of 12 or above in rural areas and they have ordered for checking of quality of ongoing works on random basis. It appears that Discoms have not understood the process of prudence check. The Commission desires that, before taking up any investment, Discoms check the need of the same in the first instance and look into cost benefit analysis thereafter. This will ensure that investments are prioritized and are made where they are really needed.

7.38. Though Discoms have made substantial investments in feeder improvement programme and feeder segregation programme, they have not reported

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the benefit desired. On the contrary, the losses have increased. Therefore, the Commission requires Discoms to submit a detailed report in this regard within a period of three months for consideration of the Commission. Similar reports be submitted on RGGVY works and RAPDRP programmes.

Timely Issue & Delivery of Bills (Direction-16)

7.39. The Commission has considered the compliance report furnished by Discoms. The Commission is of the view that a lot more is required to be done in this area. Metering, Billing and Collection are three important commercial activities which is the financial backbone of Discom. As discussed earlier and as mentioned in UDAY Scheme, use of AMR meters coupled with information about issue of bills through SMS/e-mail and availability of bills through website and allowing online payment is the need of the hour and needs no stress.

7.40. As regards defective meters, the Commission has already passed an order on 09.10.2015 directing the Discoms to replace defective meters in a time bound manner duly observing that delay in replacement of defective meters will add to their commercial losses.

7.41. The Commission observes that Discoms shall install the new meters/replace the defective meters on war footing as this is not only a statutory obligation but will also help them in energy accounting which is a must for the energy audit. The Discoms shall adhere to the schedule for installation of the AMR meters under the “UDAY Scheme”.

Change in applicability for Temporary Supply for Construction (Direction-17)

7.42. Discoms have furnished proposals which are under consideration of the Commission.

Compliance of CEA Safety Regulations

7.43. CEA has issued CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010 and CEA (Safety requirements for construction, operation and maintenance of electrical plants and electric lines) Regulations, 2011. The State Government, after pursuance of the Commission, has issued various notifications relating to the provisions and implementation of these Regulations as under:

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1.

Notification dt. 21.03.2016 relating to provisions for supply and use of electricity in multi storey building more than 15 meters in height under regulation 36(1) and Approval by Electrical Inspector under regulation 43(2) of the CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010.

2. Notification dt. 21.03.2016 relating to Electrical Safety Officer for ensuring observance of Safety measures under Regulation 5(A) of CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010.

3. Vide Notification dt. 21.03.2016, State Government has made the Rajasthan Chief Electrical Inspector and Electrical Inspectors (Powers and functions) Rules, 2016 under Clause (o) of Sub section (2) of section 180 of the Electricity Act, 2003.

4. Notification dt. 21.03.2016 relating to Earthed Terminal on Consumer’s premises under regulation 16(1) of the CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010.

5. Notification dt. 21.03.2016 relating to Deposit of printed copies under regulation 10(2) of the CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010.

6. Vide Notification dt. 21.03.2016, State Government has made the Intimation of Accidents (Form and Time of Service of Notice) Rules, 2016 under Clause (m) of Sub section (2) of section 180 of the Electricity Act, 2003 (Central Act No. 36 of 2003).

7. Notification dt. 21.03.2016 relating to periodical inspection and testing of installation under regulation 30(1) of the CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010.

8. Notification dt. 21.03.2016 relating to Installation and testing of generating units under Regulation 32 of the CEA (Measures relating to Safety and Electricity Supply) Regulations, 2010.

9.

Vide Notification dt. 31.05.2016, State Government has made the Rajasthan Electrical Inspectorate (Formation of Technical Committee and Grant of License, competency Certificate to work and permit to work) Rules,2016 under Clause (o) of sub regulation (2) of section 180 of Electricity Act, 2003 read with regulation 29(1) of the Central Electricity Authority (Measures relating to Safety and Electricity Supply) Regulations, 2010.

10.

Notification dt. 23.06.2016 relating to Appointment of Chief Electrical Inspector or Electrical Inspector and designating certain persons as Senior Electrical Inspector, Electrical Inspector, Assistant Electrical Inspector and Junior Electrical Inspector, to exercise the powers and perform the functions of Electrical inspector under Sub section (1) of the section 162 of the Electricity Act, 2003.

11. Order dt. 23.06.2016, specifying the Jurisdictional area & restrictions of Electrical Inspectors.

12. Order dt. 20.07.2016 specifying the formats for grant of license to Electrical Contractors, Supervisor Certificates, Wiremen’s Certificate etc. and permit to work as Chartered Electrical Safety Engineer.

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7.44. As per the provisions of Electricity Act, 2003, the petitioners have to strictly implement these Regulations. The Regulations also contemplate overseeing of implementation of these regulations by the Chief Electrical Inspectors/Electrical Inspectors appointed by the State Government and any non-implementation is to be dealt with by these Inspectors. The Chief Electrical Inspector and Electrical Inspectors are the watchdogs of the Safety Regulations and they shall ensure their implementation by periodical checking of any violation of the regulations. Non-implementation shall be dealt with strictly and appropriate legal action be taken. There are sufficient provisions in Electricity Act, 2003 to take penal measures including prosecution of the erring persons. The Govt. of Rajasthan should periodically review the working of Electrical Inspectors and take action if need be for non-performance of their duties. Proper implementation of safety regulations will avoid electrical accidents which are occurring in large numbers and would save precious life and limbs of the individual and the livestock. If there is any negligence on the part of the persons in charge of electrical installations, the Govt. shall seriously consider to prosecute them under the penal provisions of Electricity Act, 2003 and other Penal Acts, besides taking disciplinary action against the officers/employees concerned. If Petitioners need to spend any money for compliance of the Safety Regulations, the same can be claimed through Investment Plan/ARR and the Commission is willing to consider any additional amount spent on training of employees and for compliance of Safety Regulations during truing up exercises for FY 2015-16 and in ARR for subsequent years. UDAY Scheme

7.45. As regards the directives relating to Energy Audit, DT metering, metering, voltage wise cost of supply, prevention of theft of electricity, etc., as discussed in foregoing paras, it is observed by the Commission that the Govt. of India, with an objective to bring in financial discipline and improvement of Discom’s efficiency, has formulated a financial restructuring plan by the name “UDAY Scheme” subject to fulfilment of conditions which are almost akin to Commission’s directives. This scheme while restructuring the finances of the Discoms (which in course of time have accumulated revenue gap to an extent of almost Rs. 80,000 crores due to various reasons including financial indiscipline and inefficient working), has imposed several stringent conditions for improvement of efficiency. The “UDAY Scheme” has been

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accepted by the State of Rajasthan as well as the Discoms by signing of Memorandum Of Understanding.

7.46. Under the UDAY scheme out of the total debt of Rs. 80530 Crore at the end of September , 2015, the GOI shall facilitates the GOR to take over Rs. 40265 crore (50% of the outstanding debt) of the DISCOMs as on 30th September, 2015 in the year 2015-16 and Rs. 20133 crore (25% of the outstanding debt) in the year 2016-17;

7.47. Important commitments of Discoms as stated under the UDAY Scheme are as under:

DISCOMs to take the following measures:

a) For the 50% of the debt remaining with it as on 31st March,2016, DISCOMs shall fully/ partially issue State Government guaranteed bonds or get them converted by Banks/Fls into loans or bonds with interest not more than the Banks base rate plus 0.1%. DISCOMs shall ensure timely payment of lenders’ dues towards principal/interest for the balance debt remaining with them.

b) The DISCOMs shall pay interest to the GoR on the outstanding GoR

loan in a financial year at the rate at which GoR issued non-SLR Bonds (if asked for by GoR).

c) DISCOMs shall endeavour to reduce AT&C losses as per the

following trajectory:

However, if the target in a particular year is not met, then the DISCOMs shall strive to achieve the targets in the subsequent years so as to achieve the desired target of 15 % AT&C losses by FY 2018-19.

d) DISCOMs shall restrict power supply in areas with high or increasing

AT&C losses from 1st April 2016;

e) The DISCOMs shall endeavour to eliminate the gap between ACS and ARR by FY 2018-19;

Discom FY 2015-16 FY 2016-17 2017-18 2018-19

JdVVNL 22.4% 18% 16.5% 15%

JVVNL 28% 22% 18.5% 15%

AVVNL 24% 20% 17.5% 15%

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f) The DISCOMs shall achieve operational milestones as specified in

DDUGJY & IPDS;

g) The DISCOMs shall take the following measures for loss reduction:

(i) Undertaking 'name and shame' campaign to control power theft from time to time;

(ii) Preparing loss reduction targets at division/ circle/ zonal levels and making concerned officers responsible for achieving the loss reduction targets;

(iii) Implementing performance monitoring and management system

(MIS) for tracking the meter replacement, loss reduction and day to day progress for reporting to top management;

(iv) Achieving 100% Distribution Transformer (DT) metering by June 2018,

as per DISCOMs policy;

(v) Achieving 100% feeder metering by 30th June2016;

(vi) Undertaking energy audit up to 11KV level in rural areas by

September 2016;

(vii) Undertaking Feeder Improvement Program for network

strengthening and optimization, to be completed by March 2017;

(viii) Undertaking Physical Feeder Segregation by March 2018 based on

availability of funds sanctioned for the purpose under relevant schemes;

(ix) Installation of AMR for all consumers with consumption above 500

units/month by June 2018 and for other consumers with consumption above 200 units/ month by June 2020, subject to cost benefit analysis;

(x) Providing electricity access to 30 lakh unconnected households as

per trajectory finalized in the '24x7 Power for All' document by FY 19; and

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(xi) Implementing ERP systems for better and effective inventory

management personnel management, accounts management, etc. to reduce costs and increase efficiencies by March 2018.

h) The DISCOMs shall undertake various measures for Demand Side

Management and Energy Efficiency such as:

(i) Providing LED for domestic consumers under DELP Programme through EESL;

(ii) Undertaking consumer awareness programmes for optimum utilization of resources and to foster long-term behavioural changes; and

(iii) Replacing at least 10% of existing agriculture pumps with energy

efficient pumps by March 2019.

i) The DISCOMs shall undertake the following tariff measures:

(i) Quarterly tariff revision particularly to offset fuel price increase;

(ii) Timely filing of Tariff Petition before the RERC so that Tariff Order may be issued for the year as early as possible; and

(iii) Timely preparation of annual accounts of the DISCOMs, which shall

also enable timely filing of the Tariff Petition.

The MOU also covers the action plan for efficiency improvement. The relevant part has been extracted below:

Action Plan for Efficiency improvement

The following sections highlight the strategy/ various initiatives adopted by the three Discoms, including the resources required and implementation schedule of each initiative, in order to improve operational efficiencies and achieve financial turnaround.

1. Loss Reduction

Jaipur, Ajmer and Jodhpur Discom had AT&C loss of 32.4%, 26.77% and 25.26% respectively in FY 15, which is an increase of about 2%, 5% and same respectively, over previous year's loss level. Even though the Discoms reported 98%, 99% and 99% collection

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efficiency respectively in FY 15, high distribution losses (30.9%, 26.08% and 24.29%) resulted in high AT&C loss.

The high AT&C losses remain a concern as the Discoms losses Rs. 2.12, Rs. 1.79 and Rs. 1.63 per unit respectively of energy sold because of this. It is pertinent to note that every 1% reduction in AT&C loss will result in savings of Rs. 300 Crore per annum (for Rajasthan Discoms as a whole). Thus, reducing AT&C losses to 15% by FY 2018-2019 (target as per UDAY scheme) will result in additional cost savings of about Rs. 4,200 Crore for the Rajasthan Discoms during this period. To achieve this cost savings, a robust plan for energy management, energy accounting and loss reduction has been developed.

Before embarking on the journey of loss reduction, establishing baseline AT&C losses is a sine qua non for any Discoms. The Discoms plans to take up 100% feeder & customer metering along with regular updation of asset & consumer mapping. These initiatives will provide reliable and accurate data about the actual AT&C loss level for each feeder. This will not only help in accurate portrayal of the performance of the Discoms regarding loss reduction but also allow identification of high Joss areas and targeted approach to loss reduction.

a) Energy Audit

Feeder/DT Metering

To identify feeder-wise losses, all feeders are planned to be equipped with three phase electronic meters at sub-stations from where the feeders originate. This will enable comparison of energy sent into the feeder and the energy billed thereby helping in better estimation of AT&C losses in each feeder. 100% metering of feeders will also assist in identification of 'high-loss' feeders which will subsequently help in implementation of Discoms plan to do more load shedding on high loss feeders so as to dis-incentivize theft.

The feeder meters are being read using a hand-held Common Meter Reading Instrument (CMRI) which downloads meter data. This data is uploaded into a server for further processing. This system has been operationalized on all feeders of the Discoms. Going forward, the meter reading process is planned to be automated by acquiring the meter data remotely and processing it. The bidding documents for procurement of the required MDAS system are under preparation.

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Going forward, the Discoms also plans to capture information regarding the distribution transformer and pole to which the consumer is connected. To keep the consumer indexing information current, the utility has initiated a system of updating the consumer index when new connections are released or the network is modified. The status of feeder metering and energy audit along with the timelines is summarized in the following table:

Table A: Status of feeder metering and energy audit

Particular Initiative Target Achieved

Upto Dec.15

Timelines

JVVNL Feeder Metering (R+U) 6610 6610 Sep. 15 Feeder with the energy

audit start (Rural) 4943 3116 Jun.16

AVVNL Feeder Metering (R+U) 7292 7292 Sep. 15 Feeder with the energy


JdVVNL Feeder Metering (R+U) 9164 8979 Jun.16 Feeder with the energy


The Discoms plan to-undertake energy audit upto 11 kV level in rural areas by September 2016 SE (M&P) has been assigned the overall responsibility of this initiative. The implementation schedule for this activity is as below:

Table B: Implementation Schedule for feeder audit upto 11 kV in rural areas (%)

Particular FY 16 FY 17 FY 18 H1 H2 H1 H2 H1 H2 JVVNL/AVVNL/JdVVNL 0 50 100 100 100 100

Identification of exact pockets where loss is taking place on a particular feeder would be facilitated better once metering of Distribution Transformers is also carried out, which the Discoms plans to complete by June 2018, as per policy. The responsibility of DT metering has been assigned to SE (M&P). The implementation schedule for this activity is as below:

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Table C: Implementation Schedule for DT metering (%) Particular FY 16 FY 17 FY 18 FY 19 H1 H2 H1 H2 H1 H2 H1 H2 JVVNL/AVVNL/JdVVNL 0 0 20 40 60 80 100 100

b) Loss based load shedding:

The Discoms also plan to initiate loss-based load scheduling. This essentially means that power would be supplied for a lesser number of hours on feeders where AT&C losses are high. Discoms shall restrict power supply in areas with high or increasing AT&C losses from 1st April 2016. For this, it is essential to complete feeder metering and consumer indexing which would lead to reliable data regarding feeder wise losses.

c) Feeder Segregation

For better power management, it is desirable to have agricultural and non-agricultural consumers in rural areas on separate feeders. At present, the distribution network in rural areas is only virtually segregated which limits three phase supply to non-agricultural consumers also. If the rural feeders are physically segregated, three phase supply can be provided to domestic consumers throughout the day while limiting agricultural consumers to the block hours. Therefore, the Discoms aims to physically segregate the feeders. This will also help in better identification of areas of AT&C losses, enabling the Discoms to take a targeted approach to AT&C loss reduction.

Discoms plans to complete physical feeder segregation for villages with population greater than 3000 by March 2018 based on availability of funds sanctioned for the purpose under DDUGJY. The GoI has sanctioned schemes for feeder segregation under DDUGJY for a total amount of Rs. 665 crores for three Discoms. The responsibility of ensuring that targets and timelines are met has been handed over to SE (TW). The implementation schedule for this activity is as below:

Table D: Implementation Schedule for feeder segregation (%) Particular FY 16 FY 17 FY 18 FY 19 H1 H2 H1 H2 H1 H2 H1 H2 JVVNL/AVVNL/JdVVNL 0 0 0 40 80 100 100 100

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d) AMR Metering

AMR metering reduces human intervention. It is another measure being taken for proper billing and revenue realization. In the first phase, AMR metering at DT level and high value consumers has been planned.

As mandated in the UDAY scheme, Discoms plans to install AMR meters for all consumers with consumption above 500 units / month by June 2018 and for other consumers with consumption above 200 units / month by June 2020, subject to cost benefit analysis.

The implementation schedule for this activity is as below:

Table E: Implementation schedule for AMR meter installation (%) Particular FY 16 FY 17 FY 18 FY 19 For Consumption above 500/unit/month H1 H2 H1 H2 H1 H2 H1 H2 JVVNL/AVVNL/JdVVNL 0 0 0 25 50 75 100 100 For Consumption above 200/unit/month JVVNL/AVVNL/JdVVNL 0 0 0 0 20 30 40 50

e) Network Strengthening

To reduce technical losses and frequency of shutdowns and tripping, feeder and substation improvement programs are being implemented in the State. Under Feeder Improvement Program, sag correction, reduction in long spans and re-conditioning of transformers is being undertaken while Substation Improvement Program entails, replacing defective feeder meters, circuit breakers and roster switches. The Discoms has also taken up strengthening and augmentation of existing distribution Infrastructure by constructing more 33kV substations and load balancing on 33kV network.

Under FIP and SIP, the Discoms(JVVNL/AVVNL/JdVVNL) has completed tightening of 159,000, 117800 and 192000 loose wires and straightening of 114500, 78000 and 122000 tilted poles uptill 15th December, 2015. Also, 52%, 57% and 62% of single phase transformers and 36%, 34% and 42% of three phase transformers have been reconditioned and it is expected to complete 100% reconditioning by 31st September 2016. Total investment of Rs. 199.68 Cr., 79.71cr and 225 Cr for FIP and Rs 65.46 Cr., Rs. 92.02 Cr. and Rs. 171.50 Cr. for SIP has been estimated with SE (Plan) being assigned as the nodal officer for this initiative.

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Discoms are making all out efforts to ensure a shift from breakdown maintenance to preventive maintenance. Feeder Managers have been appointed to monitor the condition of feeders. Proper log books are maintained to ensure maintenance schedule is adhered to.

In order to keep the distribution network robust, the Discoms have also taken several other steps to ensure distribution network remains robust. These steps include the following:

1. Review and updating of technical specifications, qualifying requirements of suppliers and warranty conditions;

2. Notifying norms for technical staff for grid sub-stations;

3. Enforce warranty obligations to replace defective equipment;

4. Repair of equipment not under warranty within a specified time

frame

These measures shall be continued with renewed thrust in the coming months.

f) Vigilance Drives

As part of the Discoms efforts to reduce commercial losses, aggressive vigilance and anti-theft drives are being undertaken. A significant increase in revenue realized from vigilance has been seen as compared to the previous year.

Field officers have been directed for targeting high value consumers and complete checking by 31st January 2016. In future, vigilance drives have been proposed wherein every circle will form one team per division. Such, checkings will result in disconnections in case an instance of theft is identified. Based on these drives, each circle will identify two worst performing subdivisions in terms of AT&C losses and two worst affected patches will be identified in each subdivision. These identified patches will be checked by external teams who'll be supported by District Level Vigilance Drive Monitoring Committee. Implementation and outcome of these drives will be monitored by State Level Vigilance Drive Monitoring Committee. While electricity theft is a criminal offence, most of such cases in the past have been compounded and prosecution is

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hardly pursued. This is one of the primary challenges being faced by the Discoms as far as vigilance is concerned.

g) Implementing ERP Systems

In addition, the utilities are also planning to implement Enterprise Resource Planning (ERP) systems for better and effective inventory management, accounts management, accounts management etc. to reduce costs and increase efficiencies by March 2018 with SE (IT) in charge of the initiative. Board Resolution for implementation of the same was passed on 28th September 2015. Areas under ERP shall include HR, Payroll, Employee Self Service (ESS), Customer Service, Materials Management (with inventory management), Finance, Accounts, and Project Management. The implementation schedule for this activity is as below:

Table F: Schedule for implementation of ERP system

Particular FY 16 FY 17 FY 18 FY 19 H1 H2 H1 H2 H1 H2 H1 H2

JVVNL/AVVNL/JdVVNL

Contract to be awarded

Customization

Customization

Customization

Customization

Regular Updation

2. Demand Side Management

The cheapest and more viable option to overcome energy deficit and reduction in power procurement costs is Demand side Management and implementation of energy efficiency measures in various sectors- domestic agriculture, street lighting etc.

a) Domestic Efficient Lighting Programme (DELP)

GoI has launched Domestic Efficient Lighting program (DELP) and GoR is a key participant in this. As part of initiatives taken by GoR and Discoms to conserve energy as well as save on power purchase costs, replacement of incandescent/CFL lamps with energy efficient LED lamps are being undertaken under this program. About 200 lakh LED bulbs are" planned to be distributed under DELP by FY 18 in the state of Rajasthan.

Discoms launched LED lighting program on 4th May 2015, in order to encourage consumers to replace incandescent bulbs by LEDs and copper chokes by electronic chokes which results in voltage

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stabilization and energy efficiency thereby helping in reduction of power purchase. Under this program upto three 7W LED bulbs to every interested consumers. is provided at an initial expenses of only Rs. 10 and the rest of the cost of the bulb is recovered in 12 equal instalments as part of the consumers electricity bill.

Against the target of 84 lakh, 87 lakh and 75 lakh LEDs more than 33 lakh, 15 lakh and 11 lakh LEDs have been distributed respectively by the Discoms so far under this program. The plan is to cover the entire state having 12.6 million households for replacement of incandescent bulbs by LEDS. It is likely to save a total of 2100 MUs by FY 2018-19 leading to a savings of Rs. 850 crore (considering FY 15 power purchase cost level of Rs. 4.04/ unit) for the Rajasthan Discoms.

b) Street Lighting Programme

The State has also launched Energy Efficient Street Lighting program under which all the urban municipal bodies are being covered.

c) Agriculture Pump Sets

For introducing DSM in the agriculture sector, the Discoms will explore possibilities of replacement of inefficient agriculture pumps with energy efficient pumps. The present subsidy burden for supply of electricity to these pumps is very high. A 25-30% reduction in energy consumption is possible by replacing existing pumps with energy efficient ones. The cost benefit analysis is being done in this regard and based on the analysis a programme will be chalked out. Discoms aims to replace at least 10% of existing agriculture pumps with energy efficient pumps by March 2019.

3. Power Purchase Cost optimization

Since, the power purchase costs form bulk of the Utility's cost of supply, immediate measures need to be taken for optimization of power purchase costs.

a) Power Purchase Management

In FY 14, Rajasthan reported energy deficit of 0.3% only and was energy surplus in FY 15. It is also expected to stay energy surplus in the future with the quantum of surplus energy only on the rise. In such a scenario, it is essential to devise power sale/power purchase management strategy to benefit from surplus energy availability.

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Presently, all the functions related to power purchase and trading are carried out by a common cell - Rajasthan Discoms Power Procurement cell (RDPPC), for the three Discoms of Rajasthan. However, to streamline and bring together all the processes related to power purchases including PPA management and power trading (for effectively managing surplus energy) and to increase the focus on power purchase efficiencies, better institutional arrangements through long term staffing arrangements and enabling hiring of external experts, a new corporation- Rajasthan Urja Vikas Nigam Ltd. has been formed. It is planned to make it operational from the beginning of FY 17.

b) Purchase of short term power

The Discoms are actively working on improving its efficiency of power procurement especially to take advantage of cheaper short term power available at exchanges or through bilateral deals. RDPPC, on a daily and monthly basis, evaluates the power needs and the market trends in order to purchase power, even resorting to under- drawing power available through long term PPAs when its variable cost is higher than what is available bilaterally or through exchanges.

c) Better forecasting and load management

Discoms are also undertaking measures for accurate load forecasting so that impact of over drawl and under drawl on power purchase cost can be minimized. As on 30th September 2015, Rs. 105 Crores and Rs. 7 Crores were saved in comparison to last year in over drawl and under drawl respectively for Rajasthan as whole.

d) Strict enforcement of merit order

Merit order, based on variable cost of power available from various sources through long term PPAs has been prepared and is being followed for backing-down and boxing-up of power plants. No special dispensation has been given to the state owned power plants, which have also been included and placed in the merit order. RWNL has been asked to prepare variable cost for each unit separately rather than the whole of power plant so that inefficient units are lower in the merit order.

4. Customer Service Strategy

Rajasthan was one of the first states in India to initiate reforms in the power sector. Since 2004, Government of Rajasthan brought about

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comprehensive reforms in the power sector to bring about improvements in the efficiency of delivery system and create an environment for growth for the overall benefit of the people of the state. As a result of these initiatives, most consumers are already being provided 21-22 hours of average daily supply of quality power.

In today's times it is of utmost importance to build trust with the consumers and provide service of superior quality. The quality of services provided has to match the expectations of the customers and no business can run successfully if the match is not established. Moreover, moving forward to a scenario where there will be segregation of wire and supply business and with presence of multiple distribution licensees in one area, keeping focus on customer service is of prime importance to retain customers.

a) Access to Power

The first and foremost area of concern for any consumer is access to power supply. As per the Discoms, access measured in terms of hours of supply of electricity has been consistently good in Rajasthan - rural domestic supply hours have averaged between 21 to 22 hours in each of the three distribution companies against a target of 23 hours, over the period from April 2015 to September 2015. Average agricultural supply has also averaged close to 6 hours and 30 minutes over the same period.

However, as per the Power for All document for Rajasthan, there are 3.7 million un-electrified households in the state, of which 3.5 million are in rural areas and 0.2 million in urban areas. Of these, GoR plans to extend grid supply to around 3 million consumers by FY19. (balance consumers are either in far flung/forest/remote areas or are agri-fields or will be covered through off-grid schemes). In the roadmap prepared for Power for All, GoR has set a target of providing electricity to 6 lakh consumers each year till FY 19.

At present, the un-electrified households are being electrified under DDUGJY (erstwhile RGGVY) scheme of Govt. of India. Under this scheme, electricity connections are being provided to rural households in habitations with population of more than 100. Under the 12th plan RGGVY, GoI has approved 28 schemes, covering 27 Districts, at an estimated cost of Rs. 1453.19 Crores. Electricity connection to 13.36 lakhs households including 4.43 lakhs BPL households will be provided under these schemes.

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Recently (in August 2015), GoI has sanctioned 33 schemes of Rs. 2,819 crores under DDUGJY. 7.31 lakh rural households including 2.30 lacs BPL families in the habitations with population less than 100 will be provided electricity under these schemes. Around 10 lakh connections will be released in the existing electrified areas for which distribution network is available - 5 lakh in rural areas and an equal number in the towns. To expedite release of connections, electrification camps called 'Discom Aapke Dwar' were organized.

Over 2.24 lakh applications were received by the three Discoms of Rajasthan and more than 92000 same day connections have been released.

Over 2.83 lakh connections have been released in just a period of three months i.e. a seven times increase over the normal rate of release of connections. Survey of sarpanchs conducted by DoIT indicated that approximately 75% of sarpanchs are satisfied with the way in which the camps have been organized.

Similar initiatives are proposed to be taken to provide electricity connections.

b) Quality and Reliable supply

The successful implementation of power for all hinges on providing quality and reliable supply. To provide quality 24x7 power supply to rural areas, there is an urgent need to augment/strengthen the electricity distribution infrastructure.

In order to improve reliability of supply, as discussed in previous sections, the Discoms are strengthening the network and plans to provide separate direct three phase feeders from 33 kV substations in villages having population above 3000. Preventive maintenance is being focused upon rather than shut down maintenance. Constant monitoring of tripping on various feeders is being done in order to improve power supply quality and increase consumer satisfaction.

c) Centralized Customer Care Centres

Centralized customer care and call centres have been established with defined service levels and online monitoring and escalation mechanism. These centres have a 24 hour central toll free number to register consumer complaints. The consumers can register their complaints regarding no current, theft, burning of transformers,

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misbehaviour by Discoms employees and other technical issues including safety issues also.

Awareness about the call centre is planned to be increased especially in rural areas. The scope is also planned to be increased to include other sources like applying for new connections etc.

d) Customer Engagement

Apart from the call centres, engagement with consumers will be increased through print and electronic means. The Discoms have already started collecting/compiling mobile numbers of consumers for providing information related to billing, due date, receiving feedback from consumers etc. These shall be used for a two-way communication with the consumers. Discoms also plan to introduce more avenues to consumers for bill payment, which could be in terms of e-payment through net banking, credit/ debit card etc.

5. Tariff Measures

As per Central FRP scheme, 2012, filing of tariff petitions on time was a mandatory condition as gradual tariff hike till the full recovery of total cost of power supply from revenue to pave the way for turnaround. Further, as per the UDAY scheme, Discoms plans to eliminate the gap between ACS & ARR by FY 2018-19. For this endeavour to be successful, timely revision of tariff is of utmost importance. Discoms are committed to timely filing of tariff petitions. The Discoms had submitted petitions on Annual Revenue Requirement (ARR) and tariff revision for FY 2015-16 to the Rajasthan Electricity Regulatory Commission (RERC) in August 2015. RERC had raised request for additional information as information gaps in the petition, which the Discoms have replied to. RERC has issued public notice inviting objections and the process is expected to be completed by FY 16. Along with petition for tariff revision, regular pass through of fuel cost adjustment is also being done and attention is being paid to timely preparation and finalization of accounts.

6. Employee Engagement

a) Communication

Successful implementation of planned initiatives requires clear communication among all the Stakeholders across the value chain, including employees. In order to avoid potential roadblocks in

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implementation due to poor communication and flow of information, Discoms are using multiple internal channel of communication to reach out to employees including SMS blasts, whatsapp groups, video conferences, departmental newsletters, etc. as part of its Internal Communication Strategy. This would ensure that employees are well aware of the targets and progress of various initiatives along with their role and responsibility to help achieve the same.

b) Better accountability through KPls

Along with proper communication, Key Performance Indicators (KPIs) are also being devised for each officer in- charge on areas of AT&C loss reduction and improvement in meter/billing/ collection efficiency. The performance of officer in-charge shall be linked to KPIs achieved and will attract incentive/ penalty.

c) Incentive Scheme

In order to incentivize its employees to work towards AT&C loss reduction, GoR has recently (November 2015) approved the Discoms' proposal for an Employee Financial Incentive Scheme. Under this scheme, all the employees of the O&M, sub-divisions are eligible for a financial incentive based on their performance on a single parameter of AT&C loss reduction in their respective sub-divisions. Maximum incentive would be 1 month basic pay (Running pay band pay + Grade pay). Further, 10 outstanding achievers from each Discom would be awarded “Urja Chakra”.

7.48. It is observed that the above Scheme envisages a condition that the State Government will monitor the implementation of the Scheme on a monthly basis so that the desired results are achieved. The Commission will also look into the developments closely.

7.49. Coming to the reduction of Distribution losses, though loss reduction indicated in the scheme is higher than the trajectory provided by the Commission, the Commission desires to stick to the loss reduction trajectory given by it as inefficiency cannot be passed on to the consumers. Therefore, while passing this order, Commission has disallowed a sum of Rs. 1618 crore which represents the excess losses. This in our view shall be enough to act as a deterrent for non-compliance of the direction and no further penal action is necessary.

7.50. Discoms have contemplated that work of installation of meters on feeders

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will be got completed in a time bound manner. Considering this, the Commission observes that Discoms shall, based on the meter readings, conduct energy audit. As a parallel to installation of individual meters on unmetered consumers in particular agriculture consumer category, the Discoms may examine providing meters on feeders and at distribution transformer level and take the said data to arrive at actual consumption and also to take suitable action in case theft is noticed.

7.51. Under UDAY Scheme, the utilities are contemplating to implement Enterprise Resource Planning (ERP) systems for better and effective Material Management including inventory management to reduce costs and increase efficiencies. The Commission observes that it is a concrete and good step and should be implemented expeditiously. Further, MDs of Discoms should monitor the material management and inventory management so that adequate material is available for its works and at the same time excess purchase of material is avoided.

7.52. As regards power purchase cost optimization, the State has already taken steps to constitute a new special purpose Company namely Rajasthan Urja Vikas Nigam Limited. Govt. should ensure that the company achieves the desired results.

RE: Issue of invoking of Penal Provisions for Non Compliance of Directives

7.53. Recently the Central Govt., State Govt., and Discoms have signed MoU to undertake efficiency and other measures included in the UDAY Scheme. The Commission appreciates the effective steps taken by GOI and GOR. The Commission desires that Discoms shall equally and responsibly do their work and respond to the public for whose service they have been created.

7.54. In appeal no. 119 of 2007 in the case of Chhattisgarh State Electricity Board v/s Chhattisgarh State Electricity Regulatory Commission, while dealing with the case of non compliance of directions, the Hon’ble APTEL has held that “----Before proceeding to punish, the Commission must establish that the default or violations were contumacious. We find that the Board had made its efforts to establish call centres in order to provide customer care services although the efforts did not yield the desired result and did not satisfy the Commission. This will however not entail the consequences of violation of the Commission’s order. In our opinion, the Board should not have been visited by the penalty. We therefore allow the appeal and set aside the impugned

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order. The show cause notice stands discharged. “

7.55. Hon’ble Supreme Court in several Judgments has observed that when a party against whom complaint is made regarding non-implementation of directions is in the process of implementation of the order, no penal action need be taken.

7.56. Hon’ble Supreme Court in the case of Suresh Chandra Poddar Vs Dhaniram (2002) 1 SCC 766 has observed that “the contempt jurisdiction of the courts is not to be exercised casually but only sparingly and in very deserving cases. It is appropriate to bear in mind the adage:”It is good to have the power of a giant, but not good to use it always”.

7.57. In the present case, we have observed that the Companies have implemented some of the directions fully and some of the directions partly. For non adherence to loss reduction target given by the Commission, the Commission has not allowed the excess cost of power purchase over and above that is required to be made on the basis of loss targets even though in the earlier years 50% of such cost was allowed to be shared. This reduction as stated above is of Rs. 1618 crores. Further Commission has imposed penalty on each Discom for not adhering to directions regarding urban flat rate consumers.

7.58. It is also observed that recently the Government of Rajasthan has enacted “Rajasthan State Electricity Distribution Management Responsibility Act, 2016” to provide for responsibilities of the State Government and State Distribution Licensees to ensure financial and operational turnaround and long-term sustainability of the State-owned Distribution Licensee to enable adequate electricity supply to consumers through financial restructuring, support on sustainable basis in the areas of long term planning, corporate governance, regulatory compliances, and laying down of policy directives and various other measures connected therewith or incidental thereto.

7.59. Section 3 of the said act provides that the State Government shall lay, in each financial year during the Budget Session, before the State Legislature, a State Electricity Distribution Management Statement on the measures taken by the State Government in relation to electricity distribution in the State including, in the areas of long-term planning, consumer protection, regulatory compliance, corporate governance, financial restructuring of the State Distribution Licensee, so as to bring about the operational and financial viability of the State Distribution Licensee, on sustainable basis:

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7.60. As per Section-9 of the said Act State Government shall, twice in a year, evaluate the status of compliance by the State Distribution Licensees with the Electricity Act and rules and regulations made thereunder as also regulatory directives and policies as well as steps taken to rectify instances of non-compliances since the last such evaluation.

7.61. The action of the State Govt. in enacting the above Law is a revolutionary step which has no parallel. This action also indicates the sincerity of the State Govt. in getting the improvement in efficiency and financial health of companies.

7.62. Considering all the above and legal position as stated above, the Commission is of the view that there is no occasion to invoke the penal provisions against the Discoms at the present juncture.

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Appendix

Existing and Approved Tariff for FY 2015-16

DOMESTIC CATEGORY (LT-1 and HT-1)

(BPL, Astha Card Holders and Small Domestic having consumption upto 50 units per month)

BPL and Small Domestic Domestic Category Domestic Category

Particulars Existing Tariff Particulars Approved Tariff

Energy Charges

Fixed Charges

Energy Charges

Fixed Charges

BPL and Astha card Holders* For consumption upto first 50 units per month Rs. 3.25/ unit

Rs. 90/ connection /

month

(i) For consumption upto first 50 units per month

Rs. 3.50/ unit Rs. 100/

connection / month

Small Domestic* For consumption upto 50 units per month Rs. 3.50/ unit


month

(i) For consumption upto 50 units per month

Rs. 3.85/ unit Rs. 100/

connection / month

*Note: The BPL and Astha card Holder domestic tariff shall be exclusively applicable to individual consumer person and shall not be applicable to any institution. In case any BPL, Astha Card Holder and Small Domestic consumers has consumed more than 50 unit per month in any billing cycle, the consumer will be charged as per the applicable tariff of the respective slab under the LT-I domestic category for the additional units consumed.

General Domestic-1 Domestic Category Domestic Category

Particulars Existing Tariff Particulars Approved Tariff General Domestic-1 (Consumption upto 150 units/month) General Domestic-1 (Consumption upto 150 units/month)

Energy Charges

Fixed Charges

Energy Charges

Fixed Charges

(i) For consumption upto first 50 units per month Rs. 3.50/ unit


month


Rs. 3.85/ unit


month (ii) For consumption above 50 units and upto 150 units per month

Rs. 5.45/ unit

(ii) For consumption above 50 units and upto 150 units per month

Rs. 6.10/ unit

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Particulars Existing Tariff Particulars Approved Tariff General Domestic-2 Consumption above 150 units and upto 300 units/month )

General Domestic-2 ( Consumption above 150 units and upto 300 units/month )

Energy Charges

Fixed Charges

Energy Charges

Fixed Charges


Rs.200/ connection /

month


Rs. 3.85/ unit


month

(ii)For consumption above 50 units and upto 150 units per month

Rs. 5.45/ unit


Rs. 6.10/ unit

(iii)For consumption above 150 units and upto 300 units per month

Rs. 5.70/ unit (iii)For consumption above 150 units and upto 300 units per month

Rs. 6.40/ unit


Particulars Existing Tariff Particulars Approved Tariff General Domestic-3 (Consumption above 300 and upto 500 units/month)

General Domestic-3 (Consumption above 300 and upto 500 units/month)

Energy Charges

Fixed Charges



Rs.240/ connection

/ month


Rs. 3.85/ unit


month


Rs. 5.45/ unit


Rs. 6.10/ unit


Rs. 5.70/ unit


Rs. 6.40/ unit

(iv)For consumption above 300 units and upto 500 units per month

Rs. 6.00/ unit


Rs. 6.70/ unit

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Particulars Existing Tariff Particulars Approved Tariff General Domestic-4 (Consumption above 500 units/month) General Domestic-4 (Consumption above 500 units/month)

Energy Charges

Fixed Charges



Rs. 3.50/ unit

Rs. 260/ connection

/ month


Rs. 3.85/ unit


month


Rs. 5.45/ unit (ii)For consumption above 50 units and upto 150 units per month

Rs. 6.10/ unit


Rs. 5.70/ unit

(iii) For consumption above 150 units and upto 300 units per month

Rs. 6.40/ unit


Rs.6.00/ unit


Rs. 6.70/ unit

(v)For consumption above 500 units per month

Rs. 6.40/ unit (v)For consumption above 500 units per month

Rs. 7.15/ unit

Domestic Category (HT-1) Domestic Category Domestic Category

Particulars Existing Tariff Particulars Approved Tariff HT – Domestic (HT-1) HT – Domestic (HT-1)



For contract demand over 50 kVA

Rs. 5.50/ unit


Demand per month

For contract demand over

50 kVA Rs. 6.15/ unit


Demand per month

NON-DOMESTIC CATEGORY (LT-2 & HT-2) NDS up to 5 kW of SCL (NDS- type1)

Non-Domestic Category Non-Domestic Category Particulars Existing Tariff Particulars Approved Tariff

LT-NDS(LT-2) LT-NDS(LT-2)

Type1 (Consumption upto 100 units/month) Type1 (Consumption upto 100 units/month)

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Consumption upto first 100 units per month

Rs. 6.75 /unit Rs. 210 /

connection / month


Rs. 7.55 /unit Rs. 230 /

connection / month

(NDS- type2) Non-Domestic Category Non-Domestic Category

Particulars Existing Tariff Particulars Approved Tariff LT-NDS(LT-2) LT-NDS(LT-2)

Type 2 (Consumption above 100 units/month and upto 200 units/month)

Type 2 (Consumption above 100 units/month and upto 200 units/month)




Rs.6.75/unit Rs. 210/

connection / month


Rs. 7.55 /unit Rs. 230 /

connection / month


Rs.7.15/unit


Rs. 8.00 /unit

(NDS- type 3)

Non-Domestic Category Non-Domestic Category Particulars Existing Tariff Particulars Approved Tariff LT-NDS(LT-2) LT-NDS(LT-2)






Rs.6.75 /unit


month


Rs. 7.55 /unit

Rs. 275 / connection /

month


Rs.7.15 /unit Consumption above 100 units and upto 200 unit per month

Rs. 8.00 /unit


Rs.7.45/unit Consumption above 200 unit and upto 500 unit per month

Rs. 8.35 /unit

(NDS- type 4) Non-Domestic Category Non-Domestic Category

Particulars Existing Tariff Particulars Approved Tariff LT-NDS(LT-2) LT-NDS(LT-2)

Type 4 (Consumption above 500 units/month) Type 4 (Consumption above 500 units/month)




Rs.6.75/unit Rs. 300/

connection / month


Rs. 7.55 /unit Rs. 330 /

connection / month

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Non-Domestic Category Non-Domestic Category Particulars Existing Tariff Particulars Approved Tariff


Rs.7.15/unit


Rs. 8.00 /unit


Rs.7.45/unit


Rs. 8.35 /unit

Consumption above 500 unit per month

Rs.7.85/unit Consumption above 500 unit per month

Rs. 8.80 /unit

NDS above 5 kW of SCL

Non-Domestic Category Non-Domestic Category


NDS above 5 KW of SCL (LT-2) NDS above 5 KW of SCL (LT-2)




Rs.6.75/unit

Rs.85/ KW of SCL / month


Rs. 7.55 /unit

Rs.95/ KW of SCL / month


Rs.7.15/unit


Rs. 8.00 /unit


Rs.7.45/unit


Rs. 8.35 /unit

Consumption above 500 units per month

Rs. 7.85/unit

Rs. 95/ KW of SCL / month

Or Rs. 170 per kVA of Billing Demand per

month (If SCL is more than 18.65 KW)

Consumption above 500 units per

month Rs. 8.80 /unit

Rs. 105/ KW of SCL / month

Or Rs. 190 per kVA of Billing Demand per

month (If SCL is more than 18.65 KW)

NDS –Contract Demand Over 50 kVA HT-NDS (HT-2) HT-NDS (HT-2)

For contract demand over 50 kVA

For contract demand over 50

kVA

All units Rs.7.45/unit Rs.170/ kVA of Billing Demand

per month All units Rs. 8.35 /unit

Rs.190/ kVA of Billing Demand

per month

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PUBLIC STREET LIGHTING (LT-3)

AGRICULTURE (Metered and Flat Rate) (LT-4) Particulars Existing Tariff Particulars Approved Tariff



Agriculture Supply EC

Subsidy indicated

to be received

from Govt.


Fixed Charges

Agriculture Supply EC

Fixed Charges


Rs. 4.50 /unit

Rs. 3.60/unit

Rs. 0.90 /unit Rs. 15/HP/month of

Sanctioned Connected Load


Rs. 4.75 /unit



Rs. 5.70 /unit

Rs 3.60 /unit

Rs. 2.10 /unit

Rs. 30/HP/month of Sanctioned

Connected Load


Rs. 6.05 /unit


Particulars Existing Tariff Approved Tariff Public Street

Lighting Energy

Charges Fixed Charges Energy

Charges Fixed Charges

Population <1 Lakh

Rs. 5.85/ unit Rs. 75/ Lamp point/ month

subject to a maximum of Rs. 750 /service connection/month



Population = >1 Lakh



Rs. 7.05/ unit

Rs. 105/ Lamp point/ month subject to a maximum of Rs.

2100 /service connection/month

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Flat/ unmetered (AG/FR/LT-4) Flat/ unmetered (AG/FR/LT-4)

(i)General (getting supply in block hours)

Rs. 600 / HP/

Month

Rs. 515 / HP/

Month

Rs. 85 / HP/

Month

Rs.15/HP/month of Sanctioned

Connected Load

(i)General (getting supply in block hours)

Rs. 635 HP

/Month



Rs. 720/ HP/

Month

Rs. 490/ HP/

Month

Rs. 230/ HP/

Month

Rs. 30/HP/month of Sanctioned

Connected Load


Rs. 765 HP

/Month


SMALL INDUSTRIES (LT-5) Particulars Existing Tariff Approved Tariff

Small Industrial Service (LT-5) (Load not exceeding 18.65 kW (25HP)

Energy Charges Fixed Charges Energy Charges Fixed Charges

Upto first 500 units Rs.5.35/ unit Rs. 60/ HP/ month of

sanctioned connected load

Rs.6.00/ unit Rs. 65/ HP/ month of


Above 500 units Rs.5.75/ unit Rs. 60/ HP/ month of


Rs.6.45/ unit Rs. 65/ HP/ month of


MEDIUM INDUSTRIES (LT-6 and HT-3) Particulars Existing Tariff Approved Tariff


Medium Industrial Service (LT-6)

Rs. 6.25/ unit


connected load or Rs. 150 per kVA of Billing Demand per

month

Rs. 7.00/ unit


connected load or Rs. 165 per kVA of Billing Demand per

month

Medium Industrial Service (HT-3)

Rs. 6.25/ unit Rs. 150/ kVA of Billing Demand per month

Rs. 7.00/ unit Rs. 165/ kVA of Billing Demand per month

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BULK SUPPLY FOR MIXED LOAD (LT-7 and HT-4)

Particulars Existing Tariff Approved Tariff


Schedule ML/LT-7

Rs. 6.25/ unit


connected load or

Rs. 150 per kVA of Billing Demand per month

Rs. 7.00/ unit


connected load or

Rs. 165 per kVA of Billing Demand per month

Schedule ML/HT-4

Rs.6.25/ unit Rs. 150/kVA of Billing Demand

per month Rs. 7.00/ unit

Rs. 165/kVA of Billing Demand per month

LARGE INDUSTRIES (HT-5) Particulars Existing Tariff Approved Tariff


SCL above 150 HP &/or having Contract/Maximum Demand

above 125 kVA (HT-5)

Rs.6.50/ unit

Rs. 170/ kVA of Billing

Demand per month

Rs. 7.30/ unit Rs. 185/ kVA of

Billing Demand per month

General Note:

All existing provisions which are not modified by this order, shall continue to be in force.

of 246 RERC 552/15, 553/15, 554/15

Annexure-1

List of persons present during the public hearing at Jaipur on 25.04.2016 to 27.04.2016

S. No. Name of Objector

1. Sh. A.K.Godika, Executive Director, Rajasthan Chamber of Commerce & Industry, Jaipur

2. Sh. A.R.Mohnot 3. Sh. B.L.Jat 4. Sh. B.M.Meena, Ex.Director, Jaipur Metro 5. Sh. B.M.Sanadhya, Director, Samta Power 6. Sh. B.P.Gupta, President, Rajasthan Nagarik Manch 7. Sh. B.S.Meel 8. Sh. Bhaskar A Sawant, CMD, Jaipur Discom 9. Sh. C.B.Bairathi, Executive Member, Jaipur Chamber of Commerce &

Industry 10. Sh. Chandra Shekhar Dube,General Secretary, Rajasthan Nagarik Manch 11. Sh. C.L. Saini, Bhartiya kisan Sangh 12. Sh. D,P.Chirania, RSEB Retired Abhiyanta Association 13. Sh. D.D.Agrawal, Samta Power 14. Sh. D.M.Choudhary 15. Sh. D.S.Agrawal, Consultant,Ruddraksh Energy 16. Sh. D.S.Agrawal, RCCI 17. Sh. Dinesh Gupta 18. Sh. Girish, Indus Tower 19. Sh. G.L.Sharma 20. Sh. Gyan Singh, Secretary, Mansarower Residents Welfare Society. 21. Sh. Jagdish Narayan Sharma, General Secretary, Bharatiya Kisan Sangh 22. Sh. Jaideep Charan, DCM, Sriram 23. Sh. Kapil Kothari 24. Sh. Keshav Vyas, President,Rajasthan Bizli Workers Federation 25. Sh. Liyakat Ali, Secretary, UMAS, Jodhpur 26. Sh. Man Chand Khandela 27. Sh. M.S.Naruka 28. Sh. P.C.Tak 29. Sh. P.C.Jain 30. Sh. P.N.Mandola, Secretary, Committee for Protection of Public Properties. 31. Sh. Pradeep Choudhary, AAP 32. Sh. Prakash 33. Sh. R.B.Gupta 34. Sh. Ram Chand Sharma, President, Rajasthan Nagarik Manch 35. Sh. R.P.Gure 36. Sh. Ravi Jhanwar

of 246 RERC 552/15, 553/15, 554/15

S. No. Name of Objector 37. Sh. S.K.Bakliwal 38. Sh. S.M.Gupta 39. Sh. S.P.Garg 40. Sh. Sawai Singh, Rajasthan Nagarik Manch 41. Sh. Sunil Agrawal 42. Sh. Sunil, Bharatiya Kisan Sangh 43. Sh. Surendra Singh Rajpurohit, President RIICO, Industrial Area, Beawar 44. Sh. Suresh Agrawal, NEI 45. Sh. Tara Singh 46. Sh. Ved Prakash Sharma, General Secretary, Rajasthan Bizli Workers

Federation 47. Sh. Y.K. Boliya, Director, Samta Power

of 246 RERC 552/15, 553/15, 554/15

Annexure 2

List of abbreviations AG : Agriculture A&G : Administrative and General Expenses AMR : Automatic Meter Reading AMP : Ampere APTEL : Appellate Tribunal for Electricity ARR : Aggregate Revenue Requirement AS : Accounting Standard AT & C : Aggregate Technical and Commercial AVVNL : Ajmer Vidyut Vitran Nigam Ltd. BPL : Below Poverty Line BSNL : Bharat Sanchar Nigam Limited CAG : Comptroller & Auditor General CERC : Central Electricity Regulatory Commission CEA : Central Electrical Authority CMD : Chairman and Managing Director COD : Commercial Date of Operation CPP : Captive Power Plants CT/PT : Current Transformers/Potential Transformers DCCP : Dholpur Combined Cycle Gas based Thermal Power Plant

DELP : Domestic Efficient Lighting Programme DISCOM : Distribution Company DPS : Delayed Payment Surcharge DS : Domestic Supply DSM : Demand Side Management EA 2003 : Electricity Act, 2003 EC : Energy Charges ED : Electricity Duty EESL : Energy Efficiency Services Limited ERLDC : Eastern Region Load Dispatch Centre ERPC : Eastern Regional Power Committee FIs : Financial Institutions FR : Flat Rate FRP : Feeder Renovation Program FRP : Financial Restructuring Plan FY : Financial Year GFA : Gross Fixed Assets

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List of abbreviations GIS : Geographical Information System GoI : Government of India GoR : Government of Rajasthan GLTPP : Giral lignite Thermal Power Project GPVVY : Gram Panchayat Vidyut Vitran Yojna HP : Horse Power HT : High Tension JdVVNL : Jodhpur Vidyut Vitran Nigam Limited JVVNL : Jaipur Vidyut Vitran Nigam Limited JMRC : Jaipur Metro Railway Corporation KTPS : Kota Thermal Power Station KW : Kilo Watt kWh : Kilo Watt Hour KVA : Kilo Volt Ampere LPS : Late Payment Surcharge LT : Low Tension LTL : Long-Term Loans MIP : Medium Industrial Power MMH : Mini Micro Hydro ML : Mixed Load MoU : Memorandum of Understanding MS : Metered Supply MU : Million Unit MW : Mega Watt MYT : Multi Year Tariff NCES : Non Conventional Energy Sources NDS : Non Domestic Supply NHPC : National Hydro Power Corporation NLC : Neyveli Lignite Corporation NPCIL : Nuclear Power Corporation NTPC : National Thermal Power Corporation NRLDC : Northern Region Load Dispatch Centre NRPC : Northern Regional Power Committee O&M : Operation & Maintenance PDC : Permanent Disconnection PGCIL : Power Grid Corporation of India Ltd. PLF : Plant Load Factor

of 246 RERC 552/15, 553/15, 554/15

List of abbreviations PP : Partnership Projects PSL : Public Street Lighting PWW : Public Water Works RAPDRP : Restructured Accelerated Power Development & Reform Programme

RDPPC : Rajasthan Discoms Power Procurement Centre

RBI : Reserve Bank of India RE : Renewable Energy RERC : Rajasthan Electricity Regulatory Commission RGTPS : Ramgarh Gas Thermal Power Station RoE : Return on Equity RPO : Renewable Power Obligation RREC : Rajasthan Renewable Energy Corporation R&M : Repairs & Maintenance RVPNL : Rajasthan Vidyut Prasaran Nigam Limited RVUN : Rajasthan Vidyut Utpadan Nigam SBAR : State Bank Advance Rate SCL : Sanctioned Connected Load SERC : State Electricity Regulatory Commission SIP : Small Industrial Power SJVNL : Satluj Jal Vidyut Nigam Limited SLDC : State Load Dispatch Centre

SLM : Straight Line Method SOP : Standard Of Performance STL : Short Term Liabilities STPS : Suratgarh Thermal Power Station TVM : Tri Vector Meter T&D : Transmission & Distribution TO : Tariff Order UDAY : Ujwal Discom Assurance Yojana WPI : Wholesale Price Index

of 246 RERC 552/15, 553/15, 554/15

Power Purchase Quantum and Cost for FY 2015-16 Annexure 3 JVVNL AVVNL JdVVNL

Source of Power(Station wise)

Net Gener ation (MU)

Total Ann ual

Fixed char

ges (Rs Cr.)

Vari able Cost (Rs./ unit


Total Vari able

Cost (Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)

Total Cost JVV NL (Rs.

Cr.)


Total Vari able Cost

(Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)

Total Cost

aVVNL (Rs. Cr.)


Total Vari able Cost (Rs. Cr.)

Total Fixed Cost (Rs. Cr.)

Total Cost

JdVVNL (Rs. Cr.)

NTPC

ANTA GTPS 196.05 41.33 3.36 78.42 26.37 16.53 42.90 54.89 18.46 11.57 30.03 62.74 21.09 13.23 34.32

AURIYA GTPS 115.55 23.35 4.01 46.22 18.55 9.34 27.89 32.35 12.99 6.54 19.52 36.98 14.84 7.47 22.31

DADRI GTPS 214.17 29.81 3.60 85.67 30.86 11.92 42.78 59.97 21.60 8.35 29.95 68.54 24.68 9.54 34.22

FGUTTPS –I 60.42 11.45 2.67 24.17 6.46 4.58 11.04 16.92 4.52 3.21 7.73 19.33 5.17 3.66 8.83

FGUTTPS –II 143.53 23.09 2.67 57.41 15.31 9.24 24.55 40.19 10.72 6.46 17.18 45.93 12.25 7.39 19.64

FGUTPP III 80.70 21.57 2.66 32.28 8.58 8.63 17.21 22.60 6.01 6.04 12.05 25.82 6.87 6.90 13.77

F.S.T.P.S 45.50 5.98 2.88 18.20 5.24 2.39 7.63 12.74 3.67 1.67 5.34 14.56 4.19 1.91 6.10

K.H.S.T.P.S. I 89.47 15.94 2.44 35.79 8.74 6.38 15.12 25.05 6.12 4.46 10.59 28.63 6.99 5.10 12.10

K.H.S.T.P.S. & II 467.21 85.21 2.32 186.88 43.27 34.08 77.36 130.82 30.29 23.86 54.15 149.51 34.62 27.27 61.88

RHIND STPS 505.35 51.27 1.80 202.14 36.32 20.51 56.83 141.50 25.42 14.36 39.78 161.71 29.06 16.41 45.46

RIHAND II 503.82 64.61 1.67 201.53 33.73 25.84 59.58 141.07 23.61 18.09 41.70 161.22 26.99 20.67 47.66

RIHAND III 577.95 103.58 1.64 231.18 37.81 41.43 79.24 161.83 26.47 29.00 55.47 184.94 30.25 33.14 63.39

SINGUARLI 2230.26 110.14 1.40 892.10 124.79 44.06 168.84 624.47 87.35 30.84 118.19 713.68 99.83 35.24 135.07

TALCHAR STPS 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

KHPS-I 205.84 53.22 2.78 82.33 22.88 21.29 44.16 57.63 16.01 14.90 30.91 65.87 18.30 17.03 35.33

NCTPS 1 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

NCTPS 2 26.60 2.53 3.56 10.64 3.78 1.01 4.80 7.45 2.65 0.71 3.36 8.51 3.03 0.81 3.84

TOTAL CURRENT 5462.42 643.06 2184.97 422.70 257.23 679.92 1529.48 295.89 180.06 475.94 1747.97 338.16 205.78 543.94

NHPC

TANAKPUR HEP 45.21 6.85 1.32 18.09 2.39 2.74 5.13 12.66 1.67 1.92 3.59 14.47 1.91 2.19 4.10

SALAL HEP 110.85 5.97 1.44 44.34 6.37 2.39 8.76 31.04 4.46 1.67 6.13 35.47 5.09 1.91 7.01

CHAMERA-I 559.30 36.43 0.98 223.72 21.82 14.57 36.39 156.60 15.27 10.20 25.47 178.97 17.45 11.66 29.11

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Total Ann ual

Fixed char

ges (Rs Cr.)



Total Vari able

Cost (Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)


Cr.)



(Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)

Total Cost

aVVNL (Rs. Cr.)



(Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)

Total

Cost

JdVVNL

(Rs. Cr.)

CHAMERA-II 170.01 22.43 1.37 68.00 9.33 8.97 18.30 47.60 6.53 6.28 12.81 54.40 7.46 7.18 14.64

CHAMERA-III 131.33 29.26 2.12 52.53 11.16 11.70 22.86 36.77 7.81 8.19 16.00 42.02 8.93 9.36 18.29

URI HEP 292.79 23.27 1.12 117.12 13.11 9.31 22.42 81.98 9.18 6.52 15.70 93.69 10.49 7.45 17.94

URI HEP II 124.97 25.98 2.15 49.99 10.77 10.39 21.16 34.99 7.54 7.27 14.81 39.99 8.62 8.31 16.93

DHOLIGANGA 119.14 15.65 1.46 47.66 6.95 6.26 13.21 33.36 4.86 4.38 9.25 38.13 5.56 5.01 10.57

DULHASTI 287.78 70.38 3.20 115.11 36.89 28.15 65.04 80.58 25.82 19.71 45.53 92.09 29.51 22.52 52.03

PARBATI III 82.34 17.18 3.18 32.94 10.48 6.87 17.35 23.06 7.33 4.81 12.15 26.35 8.38 5.50 13.88

SEWA II 65.08 14.96 2.34 26.03 6.09 5.99 12.07 18.22 4.26 4.19 8.45 20.82 4.87 4.79 9.66

Kishenganga HEP (3x110)

Prior Period

TOTAL CURRENT 1988.8 268.4 795.5 135.3 107.4 242.7 556.9 94.7 75.1 169.9 636.4 108.3 85.9 194.2

NPCIL

NAPP 315.93 0.00 2.43 126.37 30.66 0.00 30.66 88.46 21.46 0.00 21.46 101.10 24.53 0.00 24.53

RAPP-I &II 1144.96 0.00 2.74 457.98 125.54 0.00 125.54 320.59 87.88 0.00 87.88 366.39 100.43 0.00 100.43

RAPP-III&IV 1076.65 0.00 2.74 430.66 118.05 0.00 118.05 301.46 82.64 0.00 82.64 344.53 94.44 0.00 94.44

RAPP-V & VI 681.58 0.00 3.41 272.63 92.92 0.00 92.92 190.84 65.04 0.00 65.04 218.11 74.34 0.00 74.34

RAPP-V 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TOTAL 3219.12 0.00 1287.65 367.17 0.00 367.17 901.35 257.02 0.00 257.02 1030.12 293.74 0.00 293.74

OTHERS

SJVNL-NATHPA-JHAKRI 633.49 86.53 1.41 253.40 35.85 34.61 70.47 177.38 25.10 24.23 49.33 202.72 28.68 27.69 56.37

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Total Ann ual

Fixed char

ges (Rs Cr.)



Total Vari able

Cost (Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)


Cr.)



(Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)

Total Cost

aVVNL (Rs. Cr.)



(Rs. Cr.)

Total

Fixed

Cost (Rs. Cr.)

Total Cost

JdVVNL (Rs. Cr.)

Rampur 174.18 29.66 1.62 69.67 11.25 11.86 23.12 48.77 7.88 8.30 16.18 55.74 9.00 9.49 18.49

NEYVELI LIGNITE CORPORATION LTD 1098.58 265.56 1.25 439.43 54.71 106.22 160.94 307.60 38.30 74.36 112.66 351.55 43.77 84.98 128.75

ARAVALI POWER CO PVT LTD 7.87 5.21 -0.41 3.15 -0.13 2.08 1.95 2.20 -0.09 1.46 1.37 2.52 -0.10 1.67 1.56

NVVN BUNDLED POWER 2209.91 186.91 3.41 883.96 301.82 74.76 376.59 618.78 211.28 52.34 263.61 707.17 241.46 59.81 301.27

Coastal Gujerat 2480.76 240.97 1.42 992.31 141.17 96.39 237.56 694.61 98.82 67.47 166.29 793.84 112.94 77.11 190.05

ADANI POWER RAJASTHAN LIMITED 8104.43 1273.42 1.94 3241.77 630.13 509.37 1139.50 2269.24 441.09 356.56 797.65 2593.42 504.11 407.49 911.60

SASAN POWER LTD 2866.85 42.78 1.22 1146.74 139.49 17.11 156.61 802.72 97.65 11.98 109.62 917.39 111.59 13.69 125.28

KARCHAM WANGTOO (PTC) 507.13 0.00 3.40 202.85 68.97 0.00 68.97 142.00 48.28 0.00 48.28 162.28 55.18 0.00 55.18

MPPMCL

TEHRI 248.21 72.04 2.96 99.28 29.37 28.81 58.19 69.50 20.56 20.17 40.73 79.43 23.50 23.05 46.55

KOTESHWAR 109.90 19.73 1.96 43.96 8.59 7.89 16.49 30.77 6.02 5.52 11.54 35.17 6.88 6.31 13.19

TALA THROUGH PTC (BHUTAN) 57.63 0.00 2.02 23.05 4.66 0.00 4.66 16.14 3.26 0.00 3.26 18.44 3.73 0.00 3.73

R.F.F. 183.60 0.00 3.99 183.60 73.26 0.00 73.26 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TOTAL 18682.54 2222.80 7583.17 1499.16 889.12 2388.28 5179.70 998.13 622.38 1620.52 5919.66 1140.72 711.30 1852.02

RVUN/ State Generation

KTPS(1 to 7) 6865.54 401.16 3.36 2746.21 922.73 160.46 1083.19 1922.35 645.91 112.33 758.23 2196.97 738.18 128.37 866.55

STPS(1 to 6) 5387.10 393.13 3.73 2154.84 803.76 157.25 961.01 1508.39 562.63 110.08 672.70 1723.87 643.00 125.80 768.80

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Total Ann ual

Fixed char

ges (Rs Cr.)



Total Vari able

Cost (Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)


Cr.)



(Rs. Cr.)

Total Fixed Cost

(Rs. Cr.)

Total Cost

aVVNL (Rs. Cr.)



(Rs. Cr.)

Total Fixe

d Cost (Rs. Cr.)

Total Cost

JdVVNL (Rs. Cr.)

DCCPP 318.87 25.74 3.09 127.55 39.41 10.30 49.71 89.28 27.59 7.21 34.80 102.04 31.53 8.24 39.77

KaTPP 2677.27 549.81 2.45 1070.91 262.37 219.92 482.30 749.64 183.66 153.95 337.61 856.73 209.90 175.94 385.84

KaTPP unit 2 423.31 59.73 2.27 169.33 38.47 23.89 62.36 118.53 26.93 16.72 43.65 135.46 30.78 19.11 49.89

CTPP (1&2) 1409.50 188.74 2.20 563.80 124.04 75.49 199.53 394.66 86.83 52.85 139.67 451.04 99.23 60.40 159.62

CTPP (3) 1087.84 186.07 2.11 435.14 91.81 74.43 166.24 304.60 64.27 52.10 116.37 348.11 73.45 59.54 132.99

Rajwest 6331.18 1420.34 1.82 2532.47 460.05 568.13 1028.18 1772.73 322.03 397.69 719.73 2025.98 368.04 454.51 822.55

CTTP 4 1274.50 188.75 1.85 509.80 94.52 75.50 170.02 356.86 66.16 52.85 119.01 407.84 75.61 60.40 136.01

GLTPP 2 233.17 34.18 1.00 93.27 9.37 13.67 23.05 65.29 6.56 9.57 16.13 74.62 7.50 10.94 18.44

RGTPS 461.92 21.96 2.71 184.77 50.07 8.78 58.85 129.34 35.05 6.15 41.20 147.81 40.06 7.03 47.08

RGTPS 3 1038.31 139.06 2.69 415.33 111.72 55.62 167.35 290.73 78.21 38.94 117.14 332.26 89.38 44.50 133.88

MAHI 65.51 25.76 0.30 26.20 0.79 10.30 11.09 18.34 0.55 7.21 7.76 20.96 0.63 8.24 8.87

MAHI MMH 0.63 0.00 3.78 0.25 0.09 0.00 0.09 0.18 0.07 0.00 0.07 0.20 0.08 0.00 0.08

MANGROL 4.21 0.00 3.78 1.68 0.64 0.00 0.64 1.18 0.45 0.00 0.45 1.35 0.51 0.00 0.51

STPS MMH 0.09 0.00 3.78 0.03 0.01 0.00 0.01 0.02 0.01 0.00 0.01 0.03 0.01 0.00 0.01

TOTAl 27578.96 3634.42 11031.58 3009.85 1453.77 4463.62 7722.11 2106.90 1017.64 3124.54 8825.27 2407.88 1163.02 3570.90

SHARED

BBMB(BHAKRA,DEHAR&PONG 2692.72 0.00

0.44

1077.09

47.65

0.00

47.65

753.96 33.36 0.00

33.36

861.67 38.12 0.00

38.12 CHAMBAL/SATPURA 801.55 0.00 320.62 0.00 224.43 0.00 0.00 256.50 0.00 0.00

TOTAL (G) 3494.27 0.00 1397.71 47.65 0.00 47.65 978.40 33.36 0.00 33.36 1118.17 38.12 0.00 38.12

NCES

WIND FORMS 4342.32 0.00 4.84 1736.93 841.03 0.00 841.03 1215.85 588.72 0.00 588.72 1389.54 672.83 0.00 672.83

SOLAR 1189.68 0.00 4.53 475.87 215.48 0.00 215.48 333.11 150.84 0.00 150.84 380.70 172.39 0.00 172.39

Total Biomass 535.35 0.00 6.37 214.14 136.39 0.00 136.39 149.90 95.47 0.00 95.47 171.31 109.11 0.00 109.11

CPP

TOTAL NCES 6067.35 0.00 4.92 2426.94 1192.90 0.00 1192.90 1698.86 835.03 0.00 835.03 1941.55 954.32 0.00 954.32

Gross Power Purchase 66493.46 6768.67

26707.54 6674.78 2707.47 9382.25 18566.76 4621.06 1895.23 6516.29 21219.15 5281.22 2165

.98 7447.19

Less: Surplus power 7009.60 0.00 4.00 4177.04 1670.82 0.00 1670.82 2479.95 991.98 0.00 991.98 352.61 141.04 0.00 141.04

Total Net Power Purchase 59483.86 6768.67 22530.50 5003.96 2707.47 7711.43 16086.81 3629.09 1895.23 5524.31 20866.54 5140.17 2165.98 7306.15

RAJASTHAN ELECTRICITY REGULATORY COMMISSION, JAIPUR Petition...

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