4.0
OBJECTIONS DURING HEARING
4.1 The representative of M/s. Utkal
Chamber of Commerce & Industry (UCCI) highlighted the following :-
4.1.1 They raised the issue of T&D loss and observed that Gridco has no right to ask
for 41% overall loss as against 35% target set by the Commission in the last tariff order.
They have also pointed out that the Gridco's proposal for increase in the load factor for
domestic and commercial categories would increase the actual power sale by more than 2000
million units in a year. This should reduce the loss level by 20%. Gridco should take
account of this while asking for 41% system loss. They further argued that meters have not
been fixed for about 85,000 consumers under Kutir Jyoti programme. If this is done, it
would reduce the system loss further. The above three measures will reduce cost of
procurement by about Rs. 500 crores in a year.
4.1.2 In their argument for reducing the power purchase
they raised the following issues :-
a) Gridco should have optimized procurement of hydro
power which was far cheaper. It is possible to purchase more hydro power than last year
because of good rains in September'98.
b) The availability of comparatively cheaper power from
Ib Valley and TTPS has been assumed on the lower side.
c) The EREB has no right to reduce the generation of
lower cost power and increase generation of higher cost power.
d) Procurement from CPPs is lower as compared to what
was assumed by OERC in 1997-98.
4.1.3 On the matter of transmission tariff and EHT loss
they put forth their views as follows:
a) Transmission charges levied @ 40 paise per unit
excluding transmission losses of 7.5% is very high.
b) PGCIL charges 11 paisa per unit as transmission
charge.
c) Gridco itself charges only 17.5 paise per unit for
both transmission charges and EHT losses for wheeling power to APSEB and to
MPSEB.
d) The EHT transmission cost of Gridco on embedded cost
basis comes to 19 paisa per unit.
e) Transmission losses have now been accurately
evaluated at 5.3%. Thus 7.5% transmission loss is on the higher side.
f) Transmission charges should be calculated on embedded
cost basis as in retail tariff.
4.1.4 In the matter of capital base and cost they
argued:-
(a) Capital base of Gridco has been increased
arbitrarily from Rs. 523 crores in 1997-98 to Rs. 1031 crores for 1998-99.
(b) Previous loss of Rs. 543 crores has been added to
the revenue requirement of Gridco without considering the subsidy claims on Govt.
amounting to Rs. 538 crores.
(c) The capital cost of assets transferred to Gridco and
OHPC by the Govt. have been uplifted from 2 to 2.5 times of the book value. This has
increased the revenue requirement of Gridco. Uplift of costs of depreciated equipment
makes the consumers to pay depreciation continuously at a higher rate instead of zero
depreciation after recovery of 90% of cost of equipment through depreciation.
4.1.5 They further pointed out that the fuel price
adjustment formulae as proposed is complicated and incorporates excess power cost, other
unadjusted costs etc. in it. These should not be included in the formula.
4.2.1 Mr. M.V. Rao, objector representing M/s. Ferro
Alloys Corporation Ltd. (FACOR) had submitted the objections to the Commission and during
the personal hearing brought to the notice that FACOR is a 100% export oriented company
and is a capital-intensive company. He said that the present tariff is too high compared
to those in foreign countries with whom the company has to compete. The price quoted for
different countries was stated to be as follows :-
Country
|
Ps./Kwh
|
Brazil
|
97
|
Norway
|
85
|
Poland
|
81
|
Sweden
|
122
|
France
|
105
|
South Africa
|
93
|
4.2.2 The next important issue pointed
out by Mr. Rao was that the charge chrome plant situated in the North-Eastern distribution
zone is availing NTPC power during off peak hours through the grid under supplementary
agreement with Gridco. FACOR contends that Gridco has to be clearly directed in the tariff
order so that Gridco and the four newly formed distribution companies would honour the
above supplementary agreement for supply of NTPC power as it was approved at the instance
of both the State and Central Governments for availing cheaper electricity required to
compete in the international market.
4.3.1 Mr. T.C. Hota, representing M/s. Indian Charge
Chrome Ltd. (ICCL), Bomikhal, Bhubaneswar in his written submission has dealt with two
principal subjects. (1) Transmission tariff and (2) Emergency power for CPP. We would be
dealing only with transmission tariff here as this order relates only to bulk supply and
transmission tariff. Emergency power for CPP will be dealt with in the retail supply
tariff order. Mr. Hota has brought to the notice of the Commission that in view of
tabulation of monthwise loss shown as below in Appendix RT-4 of Gridco's proposal,
estimated transmission loss in EHT line during the year 1997-98 at existing 7.5% is
unreasonably high.
April 1997
|
-
|
3.560%
|
May 1997
|
-
|
4.335%
|
June 1997
|
-
|
4.903%
|
July 1997
|
-
|
3.877%
|
August 1997
|
-
|
3.426%
|
September 1997
|
-
|
3.562%
|
October 1997
|
-
|
3.057%
|
November 1997
|
-
|
4.8%
|
December 1997
|
-
|
3.52%
|
January 1998
|
-
|
3.795%
|
February 1998
|
-
|
3.616%
|
March 1998
|
-
|
3.407%
|
4.3.2 It was argued that since EHT loss
figure for Gridco for the period 4/97 to 3/98 has already been indicated as 3.823%,
Gridco's claim of 5.3% towards the transmission loss was neither reasonable nor correct.
He further observed that Gridco in clause 17 of its application has suggested to consider
the transmission loss at 5.3% as a part of the system loss of 41% on the NGP basis. He
further contended that the present EHT loss being 3.386% on an average for the year
1997-98, it was not known why Gridco was trying to project a higher transmission loss of
5.3% during the next year. He suggested that the transmission loss in EHT system should
not be allowed to exceed 3%.
4.3.3 The total units received in the system is 10,815
MU for the ensuing financial year. Allowing a loss of 5.3%, the total energy transmitted
through the system has been estimated at 10,242 MU. The cost of transmission, distribution
and cost of lost units have been calculated at Rs.431 crores and has been divided by
10,242 MU to get a cost of 42.08 paise per unit. This according to Mr. Hota includes the
inflated transmission loss as well as the inflated cost of the assets of the transmission
network received from the Govt. at uplifted price.
4.3.4 The present transmission charge of 40 paise per
unit has been considered by both the State Govt. and the CEA as abnormally high. In this
connection reference was made to the summary records of the meeting taken by the Chairman,
CEA on 16th December 1997 and annexed as an Annexure XIII(1/3) to the agenda of the 261st
OCC meeting of the EREB held on 24.12.97, enclosed to as Annexure-I.
The item 5.7 of the above proceedings of discussion states: "After detail study CEA
has fixed a wheeling charge of 10 paise per KWH which comprises transmission charge and
transmission loss of around 2.5 paise per unit and 7.5 paise per unit, respectively. This
should be acceptable to Gridco."
4.3.5 Mr. Hota in his written submission has observed
that the present rate of 17.5 paise per unit charged by Gridco for export of power to MPEB
and APSEB includes both wheeling charges and loss, whereas Gridco are claiming 40 paise
per unit towards transmission and 7.5% for loss in the present tariff proposal.
4.3.6 He has also referred to a letter
No.P-II-TAR-1/98/467 dated 12.01.98 from the Chairman-cum-Managing Director of
Gridco indicating Government's view that the present rate of 7.5% transmission loss and 40
paise wheeling charges, which has been levied from 01.4.97, are considered high and State
Government has suggested a rate of 7.5% transmission loss with 20-25 paise per unit
wheeling charges to be appropriate.
4.3.7 He has also mentioned that the Maharashtra State
Electricity Board in their new policy for captive power plant has specified a wheeling
charge at 2% of the energy wheeled and a transmission loss of 4% on EHT line between
100-500 Kms.
4.3.8 Based on the above information, he has proposed
that the transmission charges should not be more than 4% towards wheeling loss and a
maximum of 10 paise per unit towards wheeling charges. An amount of 10 paise per unit for
wheeling charge will be an additional contribution to the fixed costs and higher than the
recommendations of the CEA as well as the wheeling charge of MSEB.
4.4 Mr. K.N. Jena, objector
representing M/s. OCA put forth the following objections :
i) Gridco has not submitted audited accounts for the
year 1997-98. Hence tariff revision proposal should be rejected.
ii) Loss is due to mal-administration, in-efficiency,
corruption and mismanagement.
iii) Revaluation of assets has increased the revenue
requirement of the licensee in terms of depreciation, interest, operation and maintenance
expenses, and reasonable return.
iv) Proposed tariff revision is arbitrary and does not
conform to section 26 of Reform
Act, 1995.
v) Regulatory authority is not a legally and properly
constituted body after coming into force of Reform Act, 1995, as
such, OERC has no competence and authority to increase the tariff.
vi) When no licence has been granted by the licensing
authority for transmission and distribution separately, there should not be separate bulk
supply tariff and retail supply tariff. Imposition of bulk supply tariff would neither
ensure any benefit to consumers nor it would be conducive to improvement of efficiency.

5.0 GRIDCO'S
RESPONSE TO THE OBJECTIONS
5.1 Cost of Power
Gridco submitted their response to the objections on bulk supply tariff application. With
regard to the main component of revenue requirement, namely, power purchase cost, Gridco
in their response have highlighted that the rates for the variable costs of all thermal
stations have been projected as those prevailing at the end 1997-98. No provision for
inflation during the year 1998-99 has been made. Clearly, some increase in fuel and other
operating cost is inevitable. This will be recovered through the application of fuel and
power purchase price adjustment formula proposed along with the tariff application.
Secondly, they have stressed that the availability of cheaper hydro power to the optimal
level has been taken into the power purchase plan. Orissa Hydro Power Corporation (OHPC)
contributed about 32% of the total power purchased by Gridco during 1997-98. The power
purchase plan anticipates an increase of around 10% in the availability of hydro power,
that is from 3214 MU in 1997-98 to 3536 MU in 1998-99. They have also indicated that there
has been a shortfall of total availability of hydro power for the first five months of
1998-99 to the tune of 9.4% compared to first five months of 1997-98. Because of the lower
reservoir levels compared to previous year at Balimela power house and Machhkund power
house, Gridco apprehends availability from OHPC for the year to be approximately 3,075 MU.
Against this, Gridco's projection for the year in the tariff application is 3536 MU.
Gridco has further indicated that under the prevailing arrangement with OHPC, a fixed
amount is payable to OHPC without linkage to the quantum of power supplied. Hence, the per
unit cost of power payable to OHPC will go up from Rs.0.51 to Rs.0.59 per unit. Further,
the shortfall will have to be met by the purchase of more expensive thermal power. The
estimated incremental cost will be at least Rs.83.95 crores. The average per unit pooled
cost of power purchase will, as a result, go up to at least Rs.1.257 per unit, an increase
of about 6.5%.
5.2 Procurement of power from OPGC
For 1997-98, OERC had approved a purchase of 2330.78 MU. However, actual
availability was only 2058 MU. This represented a shortfall of about 11.7%. The reduction
in generation was due to lower availability of machines, backing down due to system
constraint and backing down due to lower demand as per the instructions of EREB. For
1998-99, Gridco has projected an availability of approx. 2115 MU, which is about 2.7%
higher than the actual availability last year.
5.3 Procurement of power from
TTPS
OERC had approved a power purchase of 1600 MU from TTPS for the year 1997-98. Gridco's
present projection for 1998-99 is approx. 1771 MU, which is about 10.5% higher than the
figure approved by OERC in 1997-98. The projection is as per the generation programme
provided by the power station.
5.4 Procurement of power from
CPP
For 1997-98 OERC had approved a purchase of 905 MU from the Captive Power Plants. Against
this, the actual availability during 1997-98 was only 695 MU. The projection for the year
1998-99 has been assumed at 700 MU which is close to the actual availability for the last
year. In this connection Gridco has indicated that with the adoption of availability
tariff by EREB, Gridco would be required to pay fixed cost to central generating companies
whether or not it draws power from them. With the introduction of availability tariff, the
fixed cost liability in respect of Central Sector Power Plants will be much higher and the
variable cost will be correspondingly much lower. It will be economical for Gridco to buy
energy from Captive Power Plants only when the variable cost of the Central Power Stations
is higher than the cost of power to be purchased from Captive Power Plants. In this
regard, Gridco has given comparative figures of variable cost of different power stations
along with cost of power from CPPs which are indicated below :
|
Rs./Unit
|
OPGC
|
0.362
|
Talcher STPS
|
0.389
|
Kahalgaon TPS
|
0.615
|
Talcher TPS
|
0.623
|
Farakka STPS
|
0.678
|
CPP
|
0.770
|
5.5 Justification
for BST
In reply to objection made by M/s. Orissa Consumer Association (OCA), Gridco reiterated
that being a holder of "The Orissa Transmission & Bulk Supply
Licence, 1997 (No. 2/97)" granted by OERC under Section
15 of Reform Act, 1995, Gridco has already implemented an
internal reorganisation, separating four distribution zones from the power procurement and
transmission business. The four distribution companies have filed application for grant of
distribution and retail supply licences, which are pending with OERC. Accordingly, a bulk
supply tariff is needed to determine the rate at which power will be sold by Gridco, the
holder of Transmission & Bulk Supply Licence, to the
Distribution & Retail Supply Licensees. Gridco emphasised that unbundling of tariffs
and functional separation results in economic efficiency in the allocation of resources
and facilitates competitive market forces. A separate BST is expected to meet these
objectives. Referring to the objection of M/s. OCA, Gridco stated that even when an
application for revocation is pending with the Commission, the licensee is within its
right to file a tariff application.
5.6 Return on loans and debentures
Gridco has stated that the Sixth Schedule of Electricity (Supply) Act, 1948 provides for
inclusion of one half percentum on the outstanding loans and debentures in calculation of
the reasonable return. As outstanding loan stands at Rs.761.88 crores, this works out to
Rs.3.81 crores. This amount has not been included in the calculation of reasonable return
and only the standard rate allowed on the capital base has been included for recovery
through the bulk supply tariff for 1998-99.
5.7 Transmission Loss
Gridco in their reply to the objection made by M/s. ICCL on 17.10.98 at page 7/29 in Issue
No. 4 "Gridco is misrepresenting the transmission loss by giving misleading data. Appendix
RT-4 mentions a level of 3.823% while the cost of supply is being calculated at
5.3%" have clarified that in Appendix RTCC-3 submitted in response
to the queries from OERC the loss of 3.82% has been calculated on the basis of gross
input. For the purpose of determination of revenue requirement, transmission loss needs to
be calculated on the net input basis since only the net energy input is available in the
system for sale. Secondly, RT-4 provides information on metered gross input or gross
output. Gridco has further stated that there is no case for restricting the transmission
loss to 3% as stated by the objector as this would be totally unreasonable and not in
consonance with the existing system conditions.
|