Chhattisgarh State Electricity Regulatory Commission Raipur: CSERC Tariff Order FY 2023-24

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CHHATTISGARH STATE ELECTRICITY REGULATORY COMMISSION

RAIPUR

Chhattisgarh State Power Generation Co. Ltd. ...... P. No. 102/2022 (T)
Chhattisgarh State Power Transmission Co. Ltd ...... P. No. 94/2022 (T)
Chhattisgarh State Load Despatch Centre ...... P. No. 100/2022 (T)
Chhattisgarh State Power Distribution Co. Ltd. ...... P. No. 95/2022 (T)

Present: Hemant Verma, Chairman


Vinod Deshmukh, Member (Judicial)
Pramod Kumar Gupta, Member

In the matter of –
1. Chhattisgarh State Power Generation Company Ltd. (CSPGCL) Petition for final True-
Up of ARR of conventional thermal and hydro power plants for FY 2021-22;
2. Chhattisgarh State Power Transmission Company Ltd. (CSPTCL) Petition for final
true-up for FY 2021-22 and determination of transmission tariff for FY 2023-24;
3. Chhattisgarh State Load Despatch Centre (CSLDC) Petition for final true-up for FY
2021-22 and determination of SLDC charges for FY 2023-24;
4. Chhattisgarh State Power Distribution Company Ltd. (CSPDCL) Petition for final true-
up for FY 2021-22, and Re-Determination of ARR and Retail Tariff for FY 2023-24.

ORDER
(Passed on 28/03/2023)

1. As per provisions of the Electricity Act, 2003 (hereinafter referred as 'the Act') and
the Tariff Policy, the Commission has notified the Chhattisgarh State Electricity
Regulatory Commission (Terms and Conditions for determination of tariff according
to Multi-Year Tariff principles and Methodology and Procedure for determination of
Expected revenue from Tariff and Charges) Regulations, 2021 (hereinafter referred as
'CSERC MYT Regulations, 2021') for determination of tariff for the Generating
Company, Licensees, and CSLDC.

CSERC Tariff Order FY 2023-24 i


2. The Commission had notified the Chhattisgarh State Electricity Regulatory
Commission (Terms and Conditions for determination of tariff according to Multi-
Year Tariff principles and Methodology and Procedure for determination of Expected
revenue from Tariff and Charges) Regulations, 2015 (hereinafter referred as 'CSERC
MYT Regulations, 2015') for determination of tariff for the Generating Company,
Licensees, and CSLDC, which is applicable for truing up for FY 2021-22 for the
Generating Company, Licensees, and CSLDC.

3. This Order is passed in respect of the Petitions filed by the (i) Chhattisgarh State
Power Generation Company Ltd. (CSPGCL) for approval of final True-Up of ARR of
conventional thermal and hydro power plants for FY 2021-22, (ii) Chhattisgarh State
Power Transmission Company Ltd. (CSPTCL) for approval of final true-up for FY
2021-22 and determination of transmission tariff for FY 2023-24 (iii) Chhattisgarh
State Load Despatch Centre (CSLDC) for approval of final true-up for FY 2021-22
and determination of SLDC charges for FY 2023-24, (iv) Chhattisgarh State Power
Distribution Company Limited (CSPDCL) for final true-up for FY 2021-22, and re-
determination of ARR and retail tariff for FY 2023-24.

4. This order is passed under the provisions of Section 32(3) and Section 62 read with
Section 86(1) of the Act. The Commission, before passing the combined order on the
above petitions, has considered the documents filed along with the petitions,
supplementary information obtained after technical validation, suggestions emerging
from the applicant companies, the consumers, their representatives and other
stakeholders during the public hearing.

5. The petitions were made available on the Commission‟s website. The petitions were
also made available at the offices of the petitioners. A public notice along with the
gist of the petitions was also published in the newspapers to invite
objections/suggestions as per the procedure laid down in the Regulations. The
Commission also held a meeting with members of the State Advisory Committee on
February 20, 2023 for seeking their valuable suggestions and comments. Further, the
Commission conducted public hearings on the petitions in its office at Raipur on
February 21 & 22, 2023.

6. The Commission passed the tariff order for FY 2021-22 on August 02, 2021. The
Commission has undertaken final true-up for FY 2021-22 for CSPTCL, CSLDC,
ii CSERC Tariff Order FY 2023-24
CSPGCL and CSPDCL, based on the audited accounts submitted by the utilities and
in accordance with the provisions of the CSERC MYT Regulations, 2015. Further, the
Commission has also undertaken true-up of capital cost of the GP III integrated mine
and input price of coal from GP III mine for FY 2021-22 in accordance with the
provisions of the CSERC MYT Regulations, 2021.

7. While computing the cumulative revenue deficit/(surplus) to be allowed to CSPDCL


for FY 2023-24, the revenue deficit/(surplus) of CSPGCL, CSPTCL and CSLDC
arising out of final true-up for FY 2021-22, along with corresponding
carrying/holding cost and the impact of the review filed by CSPDCL on the tariff
order for FY 2022-23, have been considered.

8. After applying the carrying cost on revenue deficit of Rs. 447.95 Crore of CSPGCL
for FY 2021-22, the total revenue deficit up to FY 2023-24 has been approved as
Rs. 538.04 Crore, as claimed by CSPGCL.

9. In this order, the Commission has trued-up the capital cost and also determined the
input price of coal from Gare Palma -III mines, for FY 2021-22 as given in the
following Table:

Approved Capital Cost and Input Price of Coal from GP-III mines (Rs. Crore)
Particulars Unit FY 2021-22
Capital Cost as on 31.03.2022 Rs. Crore 896.23
Input Price Rs./MT 1268.29

10. The Annual fixed Cost (AFC) and Energy Charge Rate for CSPGCL stations
approved by the Commission for FY 2023-24 in its tariff order dated 13.04.2022 are
as under:

Thermal Power Stations

Sl. FY 2023-24
Particulars Units
No. HTPS DSPM KWTPP ABVTPP
1 Annual Fixed Cost Rs. Crore 672.77 434.35 580.90 1394.41
2 Energy Charge Rate
(ex-bus power plant Rs./kWh 1.574 1.688 1.339 1.838
basis)
3 Contribution to P&G Rs. Crore 150.74 55.93 33.48 91.55

CSERC Tariff Order FY 2023-24 iii


Hydro Power Station (Hasdeo Bango)

Sl. No. Particulars Units FY 2023-24


1 Approved Annual Fixed Cost Rs. Crore 24.68
2 Approved Net Generation MU 270.71
3 Approved Tariff Rs./kWh 0.912
4 Contribution to P&G Rs. Crore 4.77

The contribution to Pension and Gratuity approved by the Commission shall be


separately billed by CSPGCL on monthly basis.

CSPTCL: Tariff for FY 2023-24

11. After applying the carrying cost on the revenue deficit of Rs. 42.66 Crore of CSPTCL
for FY 2021-22, the total revenue deficit up to FY 2023-24 has been approved as
Rs. 51.24 Crore, as against the claim of CSPTCL for revenue deficit of Rs. 38.22
Crore.

12. For CSPTCL, the transmission charge for FY 2023-24 shall be as under:

Sl. Particulars Units FY 2023-24


No.
A ARR approved vide order dated 13.04.2022 for
Rs. Crore 1155.61
FY 2023-24
B Add: past year cumulative revenue deficit, with
Rs. Crore 51.24
carrying cost
C Adjusted ARR for FY 2023-24 (A+B) Rs. Crore 1206.85
D Monthly Transmission Charges for Medium-term Rs. Crore/
100.57
and Long-term Open Access Consumers (C/12) month
E Short-term Open Access Charges Rs./kWh 0.3634

Further, transmission losses of 3% for the energy scheduled for transmission at the
point or points of injection shall be recoverable from Open Access customers.

CSLDC: Charges for FY 2023-24


13. Similarly, after applying the holding cost on the revenue surplus of Rs. 2.12 Crore of
CSLDC for FY 2021-22, the total revenue surplus up to FY 2023-24 has been
approved as Rs. 2.55 Crore, as against the claim of CSLDC for revenue deficit of
Rs. 1.83 Crore.

iv CSERC Tariff Order FY 2023-24


14. For CSLDC, the charges for FY 2023-24 shall be as under:

Sr. No. Particulars Approved (Rs. Crore)


1 ARR approved vide Order dated
19.55
13.04.2022 for FY 2023-24
2 Less: Adjustment of Surplus of FY 2021-
(2.55)
22, with carrying cost
3 Adjusted ARR for FY 2023-24 (1+2) 17.00
4 System Operation Charges 13.60
5 Intra-State Market Operation Charges 3.40
6 Total SLDC Charges 17.00

15. The cumulative revenue deficit/(surplus) of CSPGCL, CSPTCL, and CSLDC for FY
2021-22 along with carrying/holding cost amounts to Rs. 586.73 Crore, as against the
claim of Rs. 578.81 Crore by the Companies.

CSPDCL: Tariff for FY 2023-24

16. CSPDCL has claimed a revenue deficit of Rs. 5319.67 Crore, as against which the
Commission has approved revenue deficit of Rs. 3837.25 Crore for FY 2021-22.
After applying the carrying cost on revenue deficit of FY 2021-22, CSPDCL has
claimed revenue deficit of Rs. 6134.77 Crore. After prudence check and due scrutiny,
the Commission approves Rs. 4321.46 Crore, as against the claim of CSPDCL for
revenue deficit of Rs. 6134.77 Crore after considering the carrying cost.

17. For FY 2023-24, CSPDCL has sought approval for ARR of Rs. 15,581.14 Crore. As
against this, the Commission, after prudence check and due scrutiny, has approved the
ARR at Rs. 17,228.31 Crore. After considering the ARR and revenue from sale of
electricity for FY 2023-24, the stand-alone revenue surplus for FY 2023-24 has been
estimated as Rs. 1,804.16 Crore, as against the stand-alone revenue surplus of
Rs. 3,763.03 Crore projected by CSPDCL for FY 2023-24.

18. CSPDCL in its petition has not factored the revenue deficit/surplus of CSPGCL,
CSPTCL and CSLDC for FY 2021-22. After considering the cumulative
deficit/surplus (including carrying cost) claimed by CSPGCL, CSPTCL and CSLDC
for FY 2021-22 in their respective petitions, the net ARR of CSPDCL for FY 2023-24

CSERC Tariff Order FY 2023-24 v


works out as Rs. 22,294.71 Crore. The Commission approves the net ARR of Rs.
21,957.00 Crore for FY 2023-24, which includes the approved revenue
deficit/(surplus) of CSPGCL, CSPTCL, and CSLDC.

19. The adjusted Average Cost of Supply (ACoS) approved for FY 2022-23 was Rs.
6.22/kWh. The adjusted ACoS has been approved as Rs. 6.58/kWh for FY 2023-24.

20. CSPDCL has projected a net deficit of Rs. 2371.73 Crore for FY 2023-24 in which
they have not considered the cumulative deficit/surplus of Rs. 578.81 Crore claimed
by CSPGCL, CSPTCL and CSLDC for FY 2021-22 in their respective petitions.

21. Considering the cumulative deficit of Rs. 578.81 Crore claimed by CSPGCL,
CSPTCL and CSLDC in their respective petitions, the effective revenue deficit of
CSPDCL works out as Rs. 2950.54 Crore. As against this, the Commission has
arrived at cumulative revenue deficit of Rs. 2924.53 Crore for CSPDCL for FY 2023-
24 which includes the approved cumulative revenue deficit of Rs. 586.73 Crore of
CSPGCL, CSPTCL and CSLDC.

22. The primary objective of the Commission is to protect the interest of the consumers
and at the same time ensuring recovery of reasonable and justified cost of the utilities.
The Commission in the previous orders as well as this order has taken various steps to
balance the interest of consumers and utilities.

23. The CSPDCL, in its petition, has not proposed any tariff hike, however, in its
subsequent submissions, CSPDCL requested for rationalized tariff for all consumer
categories required to meet the approved deficit.

24. In order to recover the cumulative revenue deficit of Rs. 2924.53 Crore and for tariff
rationalisation, the Commission has taken the following measures for FY 2023-24:

a) The ToD tariffs have been rationalized. The rebate during off-peak hours is
revised to 20% and additional charges during peak hours have been retained as
20%.

b) The tariff for 220 kV and 132 kV sub-categories under HV-4 Steel category
have been rationalized, in line with the voltage-wise tariff differential
philosophy adopted for other categories.

vi CSERC Tariff Order FY 2023-24


c) The discount of 10% on Energy Charges provided for exclusive Oxygen plants
connected up to 33 kV supply voltage under HV-3 category has been
withdrawn.

d) The discount of 25% on Energy Charges provided for Textile industries


including handlooms and powerlooms, Jute industries, and ethanol industries
categories under HV-3 category has been withdrawn.

e) The monthly power-off (non-supply) hours to be considered for HV-4 Steel


category calculation of Load Factor has been rationalized to „Nil‟ hours for
industries connected at 220 kV and 132 kV voltage, and rationalized to 30 hours
for industries connected at 33 kV and 11 kV voltage.

f) “Mines with stone crusher unit” and “Mixer and/or stone crushers” have been
included in LV-5: L.V. Industry Tariff Category.

g) “Mixer and/or stone crushers” have been moved to HV-2 (Mines Tariff
Category) from earlier HV-3 (Other Industrial and General Purpose Non-
Industrial Tariff) Category.

h) A new sub-category “Saw mill with carpenters and furniture makers” has been
introduced and included in LV-2: Non-Domestic Tariff Category.

i) The discount on Energy Charges applicable for private clinics, hospitals and
nursing homes including X-ray plant, diagnostic centres and pathological labs,
situated in rural areas as defined by Government of Chhattisgarh and all areas in
Bastar avem Dakshin Kshetra Adivasi Vikas Pradhikaran, and Sarguja avem
Uttar Kshetra Adivasi Vikas Pradhikaran Notified Vide Order dated August 22,
2005, under LV-2 and HV-3 categories has been reduced from 7% to 5%.

j) The discount on Energy Charges applicable for HV-4 Steel industries situated in
Bastar avem Dakshin Kshetra Adivasi Vikas Pradhikaran and Sarguja avem
Uttar Kshetra Adivasi Vikas Pradhikaran has been reduced from 7% to 5%.

25. Based on the above-elaborated tariff rationalisation measures, it is estimated that


CSPDCL will earn additional revenue in FY 2023-24. However, even after
considering the additional revenue from these tariff rationalisation measures, it is
estimated that revenue deficit of around Rs. 2528 Crore for FY 2023-24 will remain
unmet.

CSERC Tariff Order FY 2023-24 vii


26. The Commission is likely to introduce the Fuel and Power Purchase Adjustment
Surcharge (FPPAS) formula consistent with the Electricity (Amendment) Rules,
2022, notified by Central Govt., which may be made effective from April 1, 2023.
Further, the Commission also decides that FPPAS shall be applicable on the energy
charge.

27. The standalone ACOS for FY 2023-24 has been estimated as Rs. 5.62/kWh. The
adjusted ACoS for FY 2023-24 has been estimated as Rs. 6.58/kWh. The Average
Billing Rate (ABR) for FY 2023-24 with existing tariffs is estimated to be Rs.
6.21/kWh. Considering the tariff rationalisation measures, the estimated ABR for FY
2023-24 works out as Rs. 6.34/kWh which is higher than the ABR with the existing
tariff, i.e., Rs. 6.21/kWh with prevailing terms and conditions of tariff. The ABR for
FY 2023-24 is significantly higher than the standalone ACOS of FY 2023-24, thereby
indicating that the expenses of FY 2023-24 will be met, and the shortfall would be
only in meeting the revenue deficit due to true-up of FY 2021-22.

28. Further, it may be noted that the quantum of unmet revenue requirement for FY 2023-
24 is only an estimate at this stage, and the actual revenue deficit/(surplus), if any,
shall be addressed at the time of true-up for FY 2023-24.

29. The approved Tariff Schedule applicable is appended herewith as Schedule.

30. The Order will be applicable from 1st April, 2023 and will remain in force till March
31, 2024 or till the issue of the next Tariff Order, whichever is later.

31. The Commission directs the Companies to take appropriate steps to implement the
Tariff Order.

Sd/- Sd/- Sd/-


(PRAMOD KUMAR GUPTA) (VINOD DESHMUKH) (HEMANT VERMA)
MEMBER MEMBER (JUDICIAL) CHAIRMAN

viii CSERC Tariff Order FY 2023-24


LIST OF ABBREVIATIONS
Abbreviation Description
A&G Administrative and General
ABR Average Billing Rate
ADMS Automatic Demand Management System
AFC Annual Fixed Charges
AMC Annual Maintenance Contract
APTEL Hon‟ble Appellate Tribunal of Electricity
ARR Annual Revenue Requirement
AT&C Aggregate Technical and Commercial
BESS Battery Energy Storage System
BSP Bhilai Steel Plant
CAGR Compounded Annual Growth Rates
CEA Central Electricity Authority
CERC Central Electricity Regulatory Commission
CGS Central Generating Stations
CIP Capital Investment Plan
COD Date of Commercial Operation
CPI Consumer Price Index
CSD Consumer Security Deposit
CSEB Chhattisgarh State Electricity Board
CSERC Chhattisgarh State Electricity Regulatory Commission
CSLDC Chhattisgarh State Load Despatch Centre
CSPDCL Chhattisgarh State Power Distribution Company Limited
CSPDCL Chhattisgarh State Power Distribution Company Ltd
CSPGCL Chhattisgarh State Power Generation Company Limited
CSPGCL Chhattisgarh State Power Generation Company Ltd.
CSPHCL Chhattisgarh State Power Holding Company Limited
CSPTCL Chhattisgarh State Power Transmission Company Limited
CSPTCL Chhattisgarh State Power Transmission Company Ltd.
CSPTrCL Chhattisgarh State Power Trading Company Limited
CTU Central Transmission Utility
CWIP Capital Work in Progress

CSERC Tariff Order FY 2023-24 ix


Abbreviation Description
DA Dearness Allowances
DISCOM Distribution Company
DPC Delayed Payment Charges
DPS Delayed Payment Surcharge
DS Domestic Service
DSM Deviation settlement mechanism
DT Distribution Transformer
EHV Extra High Voltage
FCA Fuel Cost Adjustment
FY Financial Year
GCV Gross Calorific Value
GFA Gross Fixed Assets
GoCG Government of Chhattisgarh
GoI Government of India
HP Horse Power
HPO Hydro Purchase Obligation
HR Human Resource
HT High Tension
HV High Voltage
IDC Interest During Construction
IoWC Interest on Working Capital
IPDS Integrated Power Development Scheme
IPP Independent Power Producer
kcal Kilocalorie
kg Kilogram
km Kilometer
kV kilo Volt
kVA kilo Volt-Ampere
kW Kilo Watt
kWh kilo Watt-hour
LV Low Voltage
M&G Maintenance and General

x CSERC Tariff Order FY 2023-24


Abbreviation Description
MAT Minimum Alternative Tax
MAT Minimum Alternate Tax
MCLR Marginal Cost of Fund based Lending Rate
MGR Merry-Go-Round
ml Millilitre
MMC Monthly Minimum Charges
MT Metric Tonnes
MU Million Units
MYT Multi Year Tariff
NTI Non-Tariff Income
NTPC National Thermal Power Corporation Ltd.
O&M Operation and Maintenance
P&G Pension & Gratuity
PGCIL Power Grid Corporation of India Limited
PLF Plant Load Factor
PLR Prime Lending Rate
PPA Power Purchase Agreement
PTC Power Trading Corporation of India Limited
R&M Repair and Maintenance
RBI Reserve Bank of India
RDSS Revamped Distribution Sector Scheme
RE Renewable Energy
RoE Return on Equity
RPO Renewable Purchase Obligation
Rs. Rupees
RSA Revenue Sharing Agreement
SAIL Steel Authority of India Ltd.
SAMAST Scheduling, Accounting, Metering and Settlement of Transaction
SBI State Bank of India
SCADA Supervisory Control and Data Acquisition
SERC State Electricity Regulatory Commission
SLDC State Load Despatch Centre

CSERC Tariff Order FY 2023-24 xi


Abbreviation Description
SLM Straight Line Method
STPS Super Thermal Power Station
STU State Transmission Utility
T&D Loss Transmission and Distribution Loss
ToD Time of Day
TSAF Transmission System Availability Factor
TSAF Transmission Service Agreement
TVS Technical Validation Session
UDAY Ujjwal DISCOM Assurance Yojana
UI Unscheduled Interchange
UI Unscheduled Interchange
VCA Variable Cost Adjustment
WLDC Western Regional Load Despatch Center
WPI Wholesale Price Index
YoY Year-on-Year
STPS Super Thermal Power Station
STU State Transmission Utility
T&D Loss Transmission and Distribution Loss
ToD Time of Day
TSAF Transmission System Availability Factor
TSAF Transmission Service Agreement
TVS Technical Validation Session
UDAY Ujjwal DISCOM Assurance Yojana
UI Unscheduled Interchange
VCA Variable Cost Adjustment
WLDC Western Regional Load Despatch Centre
WPI Wholesale Price Index
YoY Year-on-Year

xii CSERC Tariff Order FY 2023-24


TABLE OF CONTENTS

1 BACKGROUND AND BRIEF HISTORY ...................................................................... 1

1.1 BACKGROUND ................................................................................................................... 1


1.2 THE ELECTRICITY ACT, 2003, TARIFF POLICY AND REGULATIONS .............................. 1
1.3 PROCEDURAL HISTORY .................................................................................................... 1
1.4 ADMISSION OF THE PETITION AND HEARING PROCESS ................................................... 2
1.5 STATE ADVISORY COMMITTEE MEETING ....................................................................... 3

2 HEARING PROCESS, INCLUDING THE COMMENTS MADE BY VARIOUS


STAKEHOLDERS, THE PETITIONERS’ RESPONSES AND VIEWS OF THE
COMMISSION ........................................................................................................................ 4

2.1 COMMON OBJECTIONS ..................................................................................................... 4


2.2 OBJECTIONS ON CSPGCL’S PETITION ............................................................................ 5
2.3 OBJECTIONS ON CSPTCL’S PETITION........................................................................... 10
2.4 OBJECTIONS ON CSLDC’S PETITION ............................................................................. 10
2.5 OBJECTIONS ON CSPDCL’S PETITION .......................................................................... 11

3 DETERMINATION OF INPUT COAL PRICE AT GARE PALMA-III MINE END


FOR ABVTPS ........................................................................................................................ 46

3.1 BACKGROUND ................................................................................................................. 46


3.2 CAPITAL COST ................................................................................................................ 50
3.3 PROGRESS AGAINST THE MINING PLAN ........................................................................ 63
3.4 COMPUTATION OF INPUT PRICE OF COAL ..................................................................... 63

4 TRUE-UP FOR FY 2021-22 FOR CSPGCL ................................................................. 80

4.1 BACKGROUND ................................................................................................................. 80


4.2 GENERATION CAPACITY OF EXISTING GENERATING STATIONS .................................. 80
4.3 PLANT AVAILABILITY FACTOR (PAF) ........................................................................... 81
4.4 AUXILIARY ENERGY CONSUMPTION .............................................................................. 82
4.5 GROSS GENERATION AND NET GENERATION ................................................................ 83
4.6 GROSS STATION HEAT RATE .......................................................................................... 84
4.7 SECONDARY FUEL OIL CONSUMPTION .......................................................................... 85
4.8 TRANSIT LOSS ................................................................................................................. 86
4.9 CALORIFIC VALUE AND PRICE OF FUEL ........................................................................ 87
4.10 FUEL COST ...................................................................................................................... 89
4.11 ANNUAL FIXED CHARGES FOR CSPGCL ...................................................................... 89
4.12 CAPITAL COST AND ADDITIONAL CAPITALISATION ...................................................... 89
4.13 MEANS OF FINANCE FOR ADDITIONAL CAPITALISATION.............................................. 91
4.14 DEPRECIATION ................................................................................................................ 92
4.15 RETURN ON EQUITY ........................................................................................................ 94
4.16 INTEREST AND FINANCE CHARGES ................................................................................ 96

CSERC Tariff Order FY 2023-24 xiii


4.17 NORMATIVE OPERATION AND MAINTENANCE (O&M) EXPENSES................................ 97
4.18 PENSION AND GRATUITY CONTRIBUTION .................................................................... 101
4.19 INTEREST ON WORKING CAPITAL ................................................................................ 101
4.20 NON-TARIFF INCOME ................................................................................................... 102
4.21 ASH UTILIZATION EXPENSES ....................................................................................... 104
4.22 STATUTORY CHARGES .................................................................................................. 105
4.23 AGGREGATE REVENUE REQUIREMENT FOR CSPGCL FOR FY 2021-22 ................... 105
4.24 SHARING OF GAINS AND LOSSES .................................................................................. 107
4.25 REVENUE GAP/(SURPLUS) FOR CSPGCL FOR FY 2021-22 ........................................ 111

5 TRUE-UP OF ARR FOR FY 2021-22 FOR CSPTCL ................................................ 113

5.1 BACKGROUND ............................................................................................................... 113


5.2 TRANSMISSION SYSTEM OF CSPTCL .......................................................................... 113
5.3 TRANSMISSION LOSSES ................................................................................................. 114
5.4 OPERATIONS AND MAINTENANCE (O&M) EXPENSES ................................................. 115
5.5 CONTRIBUTION TO PENSION AND GRATUITY FUND .................................................... 123
5.6 GROSS FIXED ASSETS ................................................................................................... 124
5.7 DEPRECIATION .............................................................................................................. 125
5.8 INTEREST ON LOAN ....................................................................................................... 126
5.9 RETURN ON EQUITY (ROE) AND INCOME TAX ............................................................ 127
5.10 INTEREST ON WORKING CAPITAL ................................................................................ 128
5.11 NON-TARIFF INCOME ................................................................................................... 129
5.12 INCENTIVE/PENALTY ON TRANSMISSION SYSTEM AVAILABILITY FACTOR (TSAF) . 129
5.13 AGGREGATE REVENUE REQUIREMENT (ARR) ........................................................... 130
5.14 REVENUE GAP/(SURPLUS) FOR FY 2021-22................................................................. 131
5.15 ADJUSTED ARR FOR FY 2023-24 ................................................................................. 132
5.16 TRANSMISSION CHARGES FOR FY 2023-24 ................................................................. 133

6 TRUE-UP OF ARR FOR FY 2021-22 FOR CSLDC .................................................. 135

6.1 BACKGROUND ............................................................................................................... 135


6.2 ANNUAL CHARGES FOR SLDC ..................................................................................... 135
6.3 OPERATION AND MAINTENANCE (O&M) EXPENSES ................................................... 135
6.4 CONTRIBUTION TO PENSION AND GRATUITY FUND .................................................... 138
6.5 GROSS FIXED ASSETS AND MEANS OF FINANCE .......................................................... 138
6.6 DEPRECIATION .............................................................................................................. 139
6.7 INTEREST ON LOAN ....................................................................................................... 140
6.8 RETURN ON EQUITY (ROE) AND INCOME TAX ............................................................ 141
6.9 INTEREST ON WORKING CAPITAL (IOWC) ................................................................. 141
6.10 NON-TARIFF INCOME ................................................................................................... 142
6.11 AGGREGATE REVENUE REQUIREMENT FOR CSLDC.................................................. 142
6.12 REVENUE FROM CSLDC CHARGES ............................................................................. 143
6.13 REVENUE GAP/(SURPLUS) FOR CSLDC ...................................................................... 143
6.14 SLDC CHARGES FOR FY 2023-24 ................................................................................ 144

xiv CSERC Tariff Order FY 2023-24


7 REVIEW OF ORDER FOR FY 2022-23 FOR CSPDCL ........................................... 146

7.1 BACKGROUND ............................................................................................................... 146


7.2 GROUNDS FOR REVIEW................................................................................................. 147
7.3 DISALLOWANCE OF PROVISIONING OF BANKING OF RS. 488.69 CRORE IN FY 2018-19
CAUSING NEGATIVE IMPACT ON POWER PURCHASE EXPENSES FROM CENTRAL GENERATING
STATIONS BY RS. 388.54 CRORE DURING FY 2019-20 ......................................................... 148

8 TRUE-UP OF FY 2021-22 FOR CSPDCL................................................................... 151

8.1 BACKGROUND ............................................................................................................... 151


8.2 ENERGY SALES .............................................................................................................. 151
8.3 DISTRIBUTION LOSS AND ENERGY BALANCE .............................................................. 154
8.4 INCENTIVE/DISALLOWANCE FOR OVER/UNDER-ACHIEVEMENT OF DISTRIBUTION LOSS
155
8.5 POWER PURCHASE COST .............................................................................................. 159
8.6 O&M EXPENSES ........................................................................................................... 168
8.7 CONTRIBUTION TO PENSION AND GRATUITY .............................................................. 172
8.8 CAPITAL STRUCTURE.................................................................................................... 172
8.9 DEPRECIATION .............................................................................................................. 174
8.10 INTEREST ON LOAN CAPITAL ....................................................................................... 175
8.11 INTEREST ON CONSUMER SECURITY DEPOSIT ............................................................ 176
8.12 INTEREST ON WORKING CAPITAL ................................................................................ 176
8.13 RETURN ON EQUITY ...................................................................................................... 177
8.14 NON-TARIFF INCOME ................................................................................................... 178
8.15 AGGREGATE REVENUE REQUIREMENT ....................................................................... 178
8.16 REVENUE FROM SALE OF POWER ................................................................................. 179
8.17 REVENUE GAP/(SURPLUS) ............................................................................................ 181

9 ARR OF CSPDCL FOR FY 2023-24 ............................................................................ 183

9.1 BACKGROUND ............................................................................................................... 183


9.2 SALES PROJECTIONS ..................................................................................................... 183
9.3 INTER-STATE TRANSMISSION LOSSES ......................................................................... 185
9.4 INTRA-STATE TRANSMISSION LOSSES ......................................................................... 186
9.5 DISTRIBUTION LOSSES .................................................................................................. 186
9.6 ENERGY BALANCE ........................................................................................................ 187
9.7 POWER PURCHASE QUANTUM AND COST .................................................................... 188
9.8 OTHER HEADS OF ARR ................................................................................................. 193
9.9 IMPACT OF APTEL JUDGEMENT ................................................................................. 194
9.10 AGGREGATE REVENUE REQUIREMENT FOR FY 2023-24 ............................................ 195
9.11 REVENUE FROM SALE OF POWER .................................................................................. 196
9.12 STAND-ALONE REVENUE GAP/(SURPLUS) FOR FY 2023-24 ........................................ 198
9.13 CUMULATIVE REVENUE GAP/(SURPLUS) FOR FY 2023-24 ......................................... 198

10 TARIFF PRINCIPLES AND TARIFF DESIGN ........................................................ 200

CSERC Tariff Order FY 2023-24 xv


10.1 APPROACH FOR TARIFF FOR FY 2023-24 .................................................................... 200
10.2 VOLTAGE-WISE COST OF SUPPLY FOR FY 2023-24..................................................... 200
10.3 TARIFF PHILOSOPHY FOR FY 2023-24 ......................................................................... 202
10.4 POWER FACTOR INCENTIVE AND SURCHARGE FOR LV CATEGORY ........................... 203
10.5 METHOD OF PAYMENT OF BILLS .................................................................................. 203
10.6 BILLING ON ACCUMULATED METER READING ............................................................. 203
10.7 CATEGORY-WISE TARIFF .............................................................................................. 204
10.8 MINIMUM BILLING DEMAND ........................................................................................ 208
10.9 TIME OF DAY CHARGES ................................................................................................ 208
10.10 WHEELING CHARGES ................................................................................................ 208
10.11 REVENUE AT APPROVED TARIFF .............................................................................. 209
10.12 CROSS-SUBSIDY ......................................................................................................... 210
10.13 CROSS-SUBSIDY SURCHARGE ................................................................................... 210
10.14 FUEL AND POWER PURCHASE ADJUSTMENT SURCHARGE (FPPAS) ...................... 211
10.15 PARALLEL OPERATION CHARGES ............................................................................ 212
10.16 APPLICABILITY OF ORDER........................................................................................ 212

11 TARIFF SCHEDULE FOR FY 2023-24 ...................................................................... 213

11.1 TARIFF SCHEDULE FOR LOW VOLTAGE (LV) CONSUMERS ........................................ 213
11.2 TARIFF SCHEDULE FOR HIGH VOLTAGE (HV) CONSUMERS ...................................... 229
11.3 OPEN ACCESS CHARGES ............................................................................................... 246

12 DIRECTIVES ................................................................................................................. 250

12.1 DIRECTIVE TO CSPDCL .............................................................................................. 250

xvi CSERC Tariff Order FY 2023-24


List of Tables
Table 3-1: Brief Description of GP-III Coal Block ................................................................. 47
Table 3-2: Capital Cost for GP-III mines approved by Commission in MYT Order dated
April 13, 2022 in Petition No. 1 of 2022 on provisional basis (Rs. Crore) ............................. 50
Table 3-3: Actual Capital Cost for GP-III mines based on Audited Accounts of FY 2021-22
vis-a-vis Approved Capital Cost in MYT Order dated April 13, 2022, as submitted by
CSPGCL (Rs. Crore) ............................................................................................................... 52
Table 3-4: IEDC expenses as on CoD (Rs. Crore) .................................................................. 57
Table 3-5: Approved Capital Cost of GP-III Mine for True up of FY 2021-22 (Rs. Crore) ... 61
Table 3-6: Opening GFA, Capitalisation and Closing GFA for GP-III Mines for True up of
FY 2021-22 (Rs. Crore) ........................................................................................................... 62
Table 3-7: Approved Funding of Capitalisation for GP-III Mines for FY 2021-22 (Rs. Crore)
.................................................................................................................................................. 62
Table 3-8: Depreciation Approved for FY 2021-22 (Rs. Crore) ............................................. 66
Table 3-9: Interest on Loan for GP-III mines approved for FY 2021-22 (Rs. Crore) ............. 67
Table 3-10: Approved RoE for GP-III mines for FY 2021-22 (Rs. Crore) ............................. 67
Table 3-11: Approved O&M Expenses for GP-III mines for FY 2021-22 (Rs. Crore)........... 68
Table 3-12: Interest on Working Capital Approved for GP-III mines for FY 2021-22 (Rs.
Crore) ....................................................................................................................................... 69
Table 3-13: Non-Tariff Income Approved for FY 2021-22 (Rs. Crore) ................................. 71
Table 3-14: Statutory Charges for GP-III mines for the Control Period as submitted by
CSPGCL .................................................................................................................................. 72
Table 3-15: Approved Statutory Charges for GP-III mines for FY 2021-22 (Rs. Crore) ....... 72
Table 3-16: Approved MDO Charges for GP-III mines for FY 2021-22 ................................ 73
Table 3-17: Sharing of Gains due to Higher Production Approved for FY 2021-22 between
GP-III Mine and CSPGCL Plants ............................................................................................ 74
Table 3-18: Input Price of Coal from GP-III mines for FY 2021-22 as submitted by CSPGCL
.................................................................................................................................................. 78
Table 3-19: Approved Input Price of Coal from GP-III mines for FY 2021-22 (Rs. Crore)... 78
Table 3-20: Breakup of Approved Input Price of Coal from GP-III mines FY 2021-22 ........ 79
Table 4-1: Generation Capacity (MW) of existing Generating Stations ................................. 81
Table 4-2: Actual PAF for FY 2021-22 as submitted by CSPGCL......................................... 81
Table 4-3: Approved Plant Availability Factor for FY 2021-22 ............................................. 82
Table 4-4: Auxiliary Energy Consumption for FY 2021-22 as submitted by CSPGCL ......... 82
Table 4-5: Approved Auxiliary Energy Consumption for FY 2021-22 .................................. 83
Table 4-6: Actual Gross Generation and Net Generation for FY 2021-22 as submitted by
CSPGCL (MU) ........................................................................................................................ 83

CSERC Tariff Order FY 2023-24 xvii


Table 4-7: Approved Gross Generation and Net Generation for FY 2021-22 (MU) .............. 84
Table 4-8: GSHR for FY 2021-22 (kcal/kWh) ........................................................................ 84
Table 4-9: Approved GSHR for FY 2021-22 (kcal/kWh) ....................................................... 85
Table 4-10: SFOC submitted by CSPGCL for FY 2021-22 (ml/kWh) ................................... 85
Table 4-11: Approved SFOC for FY 2021-22 (ml/kWh) ........................................................ 85
Table 4-12: Transit loss as submitted by CSPGCL for FY 2021-22 ....................................... 86
Table 4-13: Approved Transit loss for FY 2021-22 ................................................................ 87
Table 4-14: Actual Calorific Value and Price of fuels for FY 2021-22 .................................. 88
Table 4-15: Approved Calorific Value and Price of fuels for FY 2021-22 ............................. 88
Table 4-16: Actual Fuel Cost for FY 2021-22 (Rs. Crore) ...................................................... 89
Table 4-17: Approved Fuel Cost for FY 2021-22 (Rs. Crore) ................................................ 89
Table 4-18: Approved Additional Capitalisation in true up for FY 2021-22 (Rs. Crore) ...... 91
Table 4-19: Approved Means of Finance for existing stations for FY 2021-22 (Rs. Crore) .. 92
Table 4-20: Depreciation for FY 2021-22 as submitted by CSPGCL (Rs. Crore) .................. 92
Table 4-21: Depreciation approved for CSPGCL for FY 2021-22 (Rs. Crore)....................... 93
Table 4-22: Return on Equity for FY 2021-22 as submitted by CSPGCL (Rs. Crore) ........... 94
Table 4-23: Approved Return on Equity for FY 2021-22 (Rs. Crore) .................................... 95
Table 4-24: Interest & Finance Charges as submitted by CGPGCL for FY 2021-22 (Rs.
Crore) ....................................................................................................................................... 96
Table 4-25: Interest & Finance Charges approved for FY 2021-22 (Rs. Crore) ..................... 97
Table 4-26: CPI and WPI Index considered by CSPGCL ....................................................... 98
Table 4-27: O&M Expenses for FY 2021-22 submitted by CSPGCL (Rs. Crore) ................. 98
Table 4-28: Approved Normative O&M Expenses for FY 2021-22 (Rs. Crore) .................. 100
Table 4-29: Approved O&M Expenses for FY 2021-22 (Rs. Crore) .................................... 101
Table 4-30: Pension and Gratuity Contribution for FY 2021-22 as submitted by CSPGCL
(Rs. Crore).............................................................................................................................. 101
Table 4-31: IoWC for FY 2021-22 as submitted by CSPGCL (Rs. Crore) ........................... 102
Table 4-32: Approved IoWC for CSPGCL for FY 2021-22 (Rs. Crore) .............................. 102
Table 4-33: Non-Tariff Income for FY 2021-22 as submitted by CSPGCL (Rs. Crore) ...... 103
Table 4-34: Approved Non-Tariff Income in True-up for FY 2021-22 (Rs. Crore) ............. 104
Table 4-35: Ash Utilization Expenses as approved (Rs. Crore) ............................................ 104
Table 4-36: Approved ARR for CSPGCL‟s Generating Stations for FY 2021-22 (Rs. Crore)
................................................................................................................................................ 106
Table 4-37: Approved Sharing of Gains and Losses for final True-up for FY 2021-22 for
CSPGCL‟s Generating Stations ............................................................................................. 108

xviii CSERC Tariff Order FY 2023-24


Table 4-38: Revenue Gap/(Surplus) after True-up for FY 2021-22 for CSPGCL (Rs. Crore)
................................................................................................................................................ 111
Table 4-39: Revenue Gap after True-up for FY 2021-22 for CSPGCL along with carrying
cost (Rs. Crore) ...................................................................................................................... 112
Table-5-1: Physical status of transmission system of CSPTCL as on March 31, 2022......... 114
Table 5-2: Transmission Losses for FY 2021-22 as submitted by CSPTCL (MU)............... 114
Table 5-3: Gross Employee Expenses for FY 2021-22 as submitted by CSPTCL (Rs.
Crore.) .................................................................................................................................... 115
Table 5-4: Employee strength of CSPTCL as on 31st March 2022 ....................................... 115
Table 5-5: Gross R&M expenses and A&G expenses for FY 2021-22 as submitted by
CSPTCL (Rs. Crore) .............................................................................................................. 116
Table 5-6: O&M Expenses as submitted by CSPTCL for FY 2021-22 (Rs. Crore) ............. 117
Table 5-7: Additional Normative O&M Expenses as submitted by CSPTCL for FY 2021-22
(Rs. Crore.)............................................................................................................................. 118
Table 5-8: Revised Normative A&G Expenses and R&M Expenses as submitted by CSPTCL
for FY 2021-22 (Rs. Crore) ................................................................................................... 118
Table 5-9: Sharing of gain/(loss) on A&G Expenses and R&M expenses as submitted by
CSPTCL for FY 2021-22 (Rs. Crore.) ................................................................................... 119
Table 5-10: Details of Outsourced Expenses (Rs. Crore) ...................................................... 119
Table 5-11: Computation of Additional A&G expenses and R&M expenses for FY 2021-22
(Rs. Crore).............................................................................................................................. 121
Table 5-12: Approved Normative A&G Expenses and R&M Expenses for FY 2021-22 (Rs.
Crore) ..................................................................................................................................... 122
Table 5-13: Approved Actual Employee Expenses for FY 2021-22 (Rs. Crore) .................. 122
Table 5-14: Approved Actual A&G Expenses and R&M Expenses for FY 2021-22 (Rs.
Crore) ..................................................................................................................................... 122
Table 5-15: Sharing of gain/(loss) on A&G Expenses and R&M expenses for FY 2021-22 as
approved by the Commission (Rs. Crore).............................................................................. 123
Table 5-16: Contribution to P&G Fund for FY 2021-22 as approved by the Commission (Rs.
Crore) ..................................................................................................................................... 123
Table 5-17: Approved GFA Addition and Means of Finance for FY 2021-22 (Rs. Crore) .. 125
Table 5-18: Approved Depreciation for FY 2021-22 (Rs. Crore) ......................................... 125
Table 5-19: Approved Interest on Loan for FY 2021-22 (Rs. Crore) .................................... 127
Table 5-20: Approved Return on Equity for FY 2021-22 (Rs. Crore) .................................. 127
Table 5-21: Approved Interest on Working Capital for FY 2021-22 (Rs. Crore) ................. 128
Table 5-22: Approved Non-Tariff Income for FY 2021-22 (Rs. Crore) ............................... 129
Table 5-23: Approved Incentive for Higher Transmission System Availability for FY 2021-
22 (Rs. Crore)......................................................................................................................... 130

CSERC Tariff Order FY 2023-24 xix


Table 5-24: Approved ARR after true-up for FY 2021-22 (Rs. Crore) ................................. 130
Table 5-25: Revenue Gap/(Surplus) submitted by CSPTCL for FY 2021-22 (Rs. Crore) .... 131
Table 5-26: Approved Revenue Gap/(Surplus) for FY 2021-22 (Rs. Crore) ........................ 132
Table 5-27: Cumulative Gap/(Surplus) submitted by CSPTCL for FY 2023-24 (Rs. Crore)132
Table 5-28: Adjusted approved ARR for FY 2023-24 (Rs. Crore) ....................................... 133
Table 5-29: Approved STOA Charges submitted by CSPTCL for FY 2023-24 (Rs. Crore) 134
Table 6-1: O&M Expenses for FY 2021-22 (Rs. Crore) ....................................................... 135
Table 6-2: Employee strength of CSLDC as on 31st March 2022 ......................................... 136
Table 6-3: Normative A&G Expenses and R&M Expenses for FY 2021-22 as submitted by
CSLDC (Rs. Crore) ................................................................................................................ 136
Table 6-4: Sharing of gain/(loss) on A&G expenses and R&M expenses for FY 2021-22 as
submitted by CSLDC (Rs. Crore) .......................................................................................... 137
Table 6-5: Approved Normative O&M Expenses for FY 2021-22 (Rs. Crore) .................... 137
Table 6-6: Sharing of gain/(loss) on A&G expenses and R&M expenses for FY 2021-22 as
approved by the Commission (Rs. Crore).............................................................................. 138
Table 6-7: Gross Fixed Assets and its Funding for FY 2021-22 for CSLDC as approved by
the Commission (Rs. Crore) .................................................................................................. 139
Table 6-8: Depreciation for FY 2021-22 for CSLDC as approved by the Commission (Rs.
Crore) ..................................................................................................................................... 139
Table 6-9: Interest on Loan for FY 2021-22 for CSLDC approved by Commission (Rs.
Crore) ..................................................................................................................................... 140
Table 6-10: Return on Equity for FY 2021-22 for CSLDC as approved by Commission (Rs.
Crore) ..................................................................................................................................... 141
Table 6-11: IoWC approved for FY 2021-22 for CSLDC by the Commission (Rs. Crore). 142
Table 6-12: Aggregate Revenue Requirement (ARR) for FY 2021-22 approved by the
Commission (Rs. Crore) ........................................................................................................ 143
Table 6-13: Revenue Gap/(Surplus) for FY 2021-22 as submitted by CSLDC (Rs. Crore) 144
Table 6-14: Revenue Gap/(Surplus) for FY 2021-22 for CSLDC as approved by the
Commission (Rs. Crore) ........................................................................................................ 144
Table 6-15: SLDC Charges claimed by CSLDC for FY 2023-24 (Rs. Crore) ...................... 145
Table 6-16: Adjusted ARR and SLDC Charges approved for FY 2023-24 (Rs. Crore) ....... 145
Table 8-1: Approved Energy Sales for FY 2021-22 (MU) .................................................... 153
Table 8-2: Energy Balance for FY 2021-22 as submitted by CSPDCL (MU) ...................... 154
Table 8-3: Approved Energy Balance and Distribution Loss for FY 2021-22 ...................... 155
Table 8-4: Sharing of Loss on account of underachievement of Distribution loss for FY 2021-
22 as submitted by CSPDCL (Rs. Crore) .............................................................................. 156
Table 8-5: Revised Sharing of Loss on account of underachievement of Distribution loss for
FY 2021-22 as submitted by CSPDCL (Rs. Crore) ............................................................... 158

xx CSERC Tariff Order FY 2023-24


Table 8-6: Sharing of Loss approved by the Commission on account of underachievement of
Distribution loss for FY 2021-22 (Rs. Crore) ........................................................................ 159
Table 8-7: Details of „Other Charges‟ under CGS Power Purchase for FY 2021-22 (Rs.
Crore) ..................................................................................................................................... 161
Table 8-8: Revenue from Sale of Power as approved by the Commission ........................... 165
Table 8-9: Approved Power Purchase Cost after True-up for FY 2021-22 (Rs. Cr.) ............ 166
Table 8-10: Actual O&M expenses as submitted by CSPDCL (Rs. Cr.) .............................. 168
Table 8-11: Details of contract services as submitted by CSPDCL (Rs. Cr.) ....................... 168
Table 8-12: Actual O&M expenses as considered by the Commission (Rs. Crore).............. 169
Table 8-13: Revised Normative R&M and A&G Expenses for FY 2021-22 (Rs. Crore) ..... 171
Table 8-14: Sharing of (Gain)/Loss for FY 2021-22 (Rs. Cr.) .............................................. 172
Table 8-15: Capital Structure for FY 2021-22 as submitted by CSPDCL (Rs. Crore) ......... 173
Table 8-16: Approved GFA and Funding for FY 2021-22 (Rs. Crore) ................................. 174
Table 8-17: Approved Depreciation for FY 2021-22 (Rs. Crore) ......................................... 175
Table 8-18: Approved Interest Expenses for FY 2021-22 (Rs. Crore) .................................. 176
Table 8-19: Approved Interest on CSD for FY 2021-22 (Rs. Crore) .................................... 176
Table 8-20: Approved IoWC for FY 2021-22 (Rs. Crore) .................................................... 177
Table 8-21: Approved RoE for FY 2021-22 (Rs. Crore) ....................................................... 178
Table 8-22: Approved Non-Tariff Income for FY 2021-22 (Rs. Crore) ............................... 178
Table 8-23: Approved ARR for FY 2021-22 (Rs. Crore) ...................................................... 179
Table 8-24: Additional Revenue from Agriculture Category for FY 2021-22 ...................... 180
Table 8-25: Approved Revenue for FY 2021-22 (Rs. Crore) ................................................ 181
Table 8-26: Approved Revenue Gap/(Surplus) for FY 2021-22 (Rs. Crore) ........................ 182
Table 9-1: Category-Wise Sales Projected by CSPDCL for FY 2023-24 ............................. 184
Table 9-2: Approved Category-Wise Sales for FY 2023-24 (MU) ....................................... 185
Table 9-3: Approved Distribution Losses for FY 2023-24 (%) ............................................. 187
Table 9-4: Energy Balance Projected by CSPDCL for FY 2023-24 (MU) ........................... 187
Table 9-5: Approved Energy Balance for FY 2023-24 ......................................................... 188
Table 9-6: RPO Target for FY 2023-24 (%) .......................................................................... 189
Table 9-7: RE Capacity Addition envisaged for FY 2023-24 ............................................... 190
Table 9-8: Approved Power Purchase Quantum and Cost for FY 2023-24 .......................... 192
Table 9-9: Other Components of ARR as claimed by CSPDCL for FY 2023-24 ................. 193
Table 9-10: Impact of APTEL Judgment allowed in FY 2023-24 (Rs. Crore) ..................... 195
Table 9-11: Approved ARR for CSPDCL for FY 2023-24 (Rs. Crore) ................................ 195

CSERC Tariff Order FY 2023-24 xxi


Table 9-12: Revenue from sale of power at existing tariff for FY 2023-24 as submitted by
CSPDCL (Rs. Crore) ............................................................................................................. 196
Table 9-13: Revenue from sale of power at existing tariff for FY 2023-24 as computed by the
Commission (Rs. Crore) ........................................................................................................ 197
Table 9-14: Standalone Revenue Gap/(Surplus) for FY 2023-24 (Rs. Crore) ...................... 198
Table 9-15: Cumulative Revenue Gap/(Surplus) for CSPDCL for FY 2023-24 as submitted
by CSPDCL (Rs. Crore) ........................................................................................................ 198
Table 9-16: Cumulative Revenue Gap/(Surplus) for CSPDCL for FY 2023-24 as approved by
the Commission (Rs. Crore) .................................................................................................. 199
Table 10-1: Average Cost of Supply (Rs./kWh) for CSPDCL for FY 2023-24 ................... 200
Table 10-2: VCoS for FY 2023-24 as calculated by Commission ........................................ 201
Table 10-3: Revenue in FY 2023-24 at Tariffs approved by the Commission ...................... 209
Table 10-4: Cross-subsidy with Existing tariff and Approved tariff ..................................... 210

xxii CSERC Tariff Order FY 2023-24


1 BACKGROUND AND BRIEF HISTORY
1.1 Background
The Chhattisgarh State Electricity Board (CSEB) was restructured by the Government
of Chhattisgarh (GoCG) in pursuance of the provisions of Part XIII of the Electricity
Act, 2003. GoCG, vide notification No. 1-8/2008/13/1 dated December 19, 2008. The
erstwhile CSEB was unbundled into five different Companies, viz., Chhattisgarh State
Power Generation Company Limited (CSPGCL), Chhattisgarh State Power
Transmission Company Limited (CSPTCL), Chhattisgarh State Power Distribution
Company Limited (CSPDCL), Chhattisgarh State Power Trading Company Limited
(CSPTrCL), and Chhattisgarh State Power Holding Company Limited (CSPHCL).
The assets and liabilities of the erstwhile CSEB have been allocated to the successor
Companies w.e.f. January 1, 2009 according to the provisions of the CSEB Transfer
Scheme Rules, 2010.

1.2 The Electricity Act, 2003, Tariff Policy and Regulations


Section 61 of the Electricity Act, 2003 (herein after referred as „the EA, 2003‟ or „the
Act‟) stipulates the guiding principles for determination of tariff by the Commission
and mandates that the tariff should progressively reflect the cost of supply of
electricity, reduce cross subsidy, safeguard consumers interest and recover the cost of
electricity in a reasonable manner. This Section also stipulates that the Commission
while framing the Tariff Regulations shall be guided by the principles and
methodologies specified by the Central Electricity Regulatory Commission for
determination of the tariff applicable to generating companies and transmission
licensees.
Section 62 of the Act stipulates that the Commission shall determine the tariff for:
 Supply of electricity by a Generating Company to a Distribution Licensee;
 Transmission of electricity;
 Wheeling of electricity; and
 Retail sale of electricity.
The Tariff Policy notified by the Government of India in January 2006, as well as the
amended Tariff Policy notified in January 2016, provides the framework to balance
the conflicting objectives of attracting investments to ensure availability of quality
power and protecting the interest of consumers by ensuring that the electricity tariffs
are affordable.

1.3 Procedural History


The Commission notified the Chhattisgarh State Electricity Regulatory Commission
(Terms and Conditions for determination of tariff according to Multi-Year Tariff
principles and Methodology and Procedure for determination of Expected revenue
from Tariff and Charges) Regulations, 2015 (hereinafter referred to as CSERC MYT
Regulations, 2015) on September 9, 2015 for the Control Period from FY 2016-17 to
FY 2020-21. The Commission vide public notice CSERC letter 03/CSERC/Tariff
2020/1228 dated November 26, 2020 has notified the extension of CSERC MYT

CSERC Tariff Order FY 2023-24 1


Regulations, 2015 for the next year, i.e., 2021-22. Accordingly, CSPGCL, CPSTCL
and CSLDC had filed Petitions for final true-up for FY 2019-20 and ARR for FY
2021-22 while CSPDCL filed Petitions for final true-up for FY 2018-19 and FY
2019-20 and ARR & Retail Supply Tariff for FY 2021-22 for which the Commission
issued order on August 02, 2021.
Further, the Commission notified the Chhattisgarh State Electricity Regulatory
Commission (Terms and Conditions for determination of tariff according to Multi-
Year Tariff principles and Methodology and Procedure for determination of Expected
revenue from Tariff and Charges) Regulations, 2021 (hereinafter referred as 'CSERC
MYT Regulations, 2021') for determination of tariff for the Generating Company,
Licensees, and CSLDC.
In accordance with CSERC MYT Regulations 2015 and CSERC MYT Regulations
2021, CSPGCL filed the Petition for approval of final true-up for FY 2021-22 on
15/12/2022 which was registered as Petition No. 102 of 2022. CSPTCL filed the
Petition for approval of final true-up for FY 2021-22 and determination of
transmission tariff for FY 2023-24 on 30/11/2022 which was registered as Petition
No. 94 of 2022. Also, CSLDC filed the Petition for approval of final true-up for FY
2021-22 and determination of SLDC charges for FY 2023-24 on 12/12/2022, which
was registered as Petition No.100 of 2022. CSPDCL filed the Petition for approval of
final true-up for FY 2021-22, and determination of ARR and Retail Supply Tariff for
FY 2023-24 on 28/11/2022, which was registered as Petition No. 95 of 2022.
In this instant Order, the Commission has undertaken the final true-up for FY 2021-22
in accordance with the provisions of the MYT Regulations, 2015 and determination of
Tariff for FY 2023-24 for CSPTCL, CSLDC and CSPDCL in accordance with the
provisions of the MYT Regulations, 2021.

1.4 Admission of the Petition and Hearing Process


The Petitions filed by CSPDCL, CSPTCL, CSLDC, and CSPGCL were registered on
01/12/2022, 01/12/2022, 14/12/2022 and 15/12/2022 respectively.
The Companies were directed to publish the abridged version of the Petition in Hindi
and English newspapers for inviting comments/objections/suggestions from all the
stakeholders. The Petitions were made available on the website of the Commission as
well as on the Petitioners' websites. As required under Clause 21 of the CSERC
(Details to be furnished by licensee etc.) Regulations, 2004, notices inviting
comments/objections/suggestions from the stakeholders on the above proposals, were
published by the Petitioners in the leading newspapers of the State.
A period of twenty-one (21) days was given for submission of written objections and
suggestions by the public. The Companies were also directed to submit written replies
to the Commission with copies endorsed to the objectors.
In order to have better clarity on the data submitted by the Petitioners and to remove
inconsistency in the data, the Technical Validation Sessions (TVS) were held on
24/01/2023 and 25/01/2023 with the Petitioners. During the TVS, additional
information required for processing of the Petitions was sought from the Petitioners.
The Petitioners submitted the additional information sought during TVS.

2 CSERC Tariff Order FY 2023-24


The objections and suggestions from stakeholders were received on the Petitions filed
by CSPGCL, CSPTCL, CSPDCL and CSLDC. The list of persons who filed the
written submissions is annexed as Annexure-I.
Public hearing was held on 21/02/2023 and 22/02/2023. The Commission has ensured
that the due process as contemplated under the law to ensure transparency and public
participation was followed at every stage and adequate opportunity was given to all
the persons to offer their views. The list of persons who submitted comments during
the hearing is annexed as Annexure-II.
The issues raised by the stakeholders along with the response of the Petitioners‟ and
views of the Commission are elaborated in Chapter 2 of this order.

1.5 State Advisory Committee Meeting


A copy of the abridged Hindi and English version of the Petitions were also sent to all
the members of the State Advisory Committee of the Commission for their comments.
A meeting of the State Advisory Committee was convened on 20 February, 2023 to
discuss the Petitions and seek inputs from the Committee. CSPGCL, CSPTCL,
CSLDC and CSPDCL gave presentations in the meeting on the salient features of
their petitions. Various aspects of the petitions were discussed by the Members of the
Committee in the meeting. The list of the SAC Members who participated in the
meeting in annexed as Annexure III.
The following suggestions and objections were submitted:
a) CSPDCL should refrain from signing any further PPA because it has already
signed more than sufficient PPAs and is unable to sell the same.
b) Surplus power available with CSPDCL should be utilized for manufacturing
Hydrogen.
c) The Commission should consider Aggregate Technical and Commercial
(AT&C) loss to evaluate the performance of CSPDCL.
d) CSPDCL should not write-off the arrears of consumers.
e) CSPDCL should prepare action plan for utilization of excess solar injection in
near future.
f) CSPDCL should be directed to meet its RPO target.

CSERC Tariff Order FY 2023-24 3


2 HEARING PROCESS, INCLUDING THE COMMENTS MADE BY VARIOUS
STAKEHOLDERS, THE PETITIONERS’ RESPONSES AND VIEWS OF THE
COMMISSION

2.1 Common Objections


2.1.1 Contribution to Pension and Gratuity Fund
The objector submitted that companies have contributed Rs. 546.34 Crore to the
pension trust in FY 2022-23. It is pertinent to mention here that total contribution of
Rs. 706.65 Crore was to be submitted in the pension trust during FY 2022-23.
Therefore, an amount of Rs. 160.31 Crore has yet to be submitted to the pension trust.
In this context, objector has requested the Commission to direct the State Power
Companies to deposit the short fall amount on priority basis.
Another objector submitted that in the true-up petitions filed by CSPGCL, CSPTCL
and CSPDCL, expenses towards Pension and Gratuity liability has been restricted to
the amount of contribution made in pension trust on actual basis whereas they have
accounted revenue from operation on accrual basis.
The objector further submitted that this deliberate attempt of claiming less than actual
in true-up and estimating lesser expenses than what it should be is causing undue
benefit to present consumers, at the cost of reduction in corpus of Gratuity and
Pension Fund. This is creating uncertainty among employees of State Power
Companies and will burden the future consumers. Total corpus of the Gratuity and
Pension Fund was around Rs. 5000 crore as on 31/03/2018, which has reduced to
Rs. 4700 crore as on 31/03/2022. And this reduction in corpus happened when there is
already huge deficit of around Rs. 10,000 crore as per latest actuarial analysis.

The objector requested the Commission that during true-up of ARR of previous years,
the expenses towards payment of pension and gratuity should be considered on the
basis of actual outflow from the Gratuity and Pension Fund with carrying cost and not
on the basis of contribution to the fund by State Power Companies. The objector also
requested that ARR for future years of all State Power Companies should be approved
by considering appropriate estimation of the expenses towards payment of retirement
benefits for Gratuity and Pension for all the retirees or pensioners of the State Power
Companies. Some additional allocation to the fund should also be made in the ARR to
reasonably fill the gap or deficit of the Gratuity and Pension Fund between actual
available fund and requirement of fund as per actuarial analysis/ valuations so that
deficit of previous years can be filled up.
Another Objector has requested the Commission to make such provision in relation to
contribution to the pension trust so that a corpus of Rs. 18,000 Crore can be created.

Petitioner’s Reply
CSPGCL, CSPTCL and CSLDC have submitted that they have deposited full amount
to the pension trust during FY 2022-23 as per the tariff order. CSPDCL has submitted
that it has deposited full contribution as specified in the tariff order for FY 2022-23 in
the month of December 2022.
CSPDCL submitted that it is contributing to Pension and Gratuity Trust Fund in the
manner approved by the State Commission in its tariff order time to time. As per the

4 CSERC Tariff Order FY 2023-24


tariff order dtd. 02.10.2021, the Commission has approved contribution towards
pension and gratuity amount to Rs. 449.48 Crore and CSPDCL has contributed to a
same amount of contribution towards pension and gratuity. CSPDCL submitted that
the matter (corpus of Rs. 18000 Crore) is not related to present petition.

Commission’s View
The instant petition pertains to true up for FY 2021-22 for which the CSERC MYT
Regulations, 2015 are applicable and Regulation 32 of the CSERC MYT Regulations,
2015 specifies that the contribution to the fund shall be decided by the Commission
on the basis of actuarial analysis, expected pension outflow for the State Power
Companies and availability of fund with the pension trust. Accordingly, the
Commission has allowed the contribution to fund as approved in this Order.

2.2 Objections on CSPGCL’s petition


2.2.1 Capacity Charges for Marwa TPP/ ABVTPP
The objector, submitted that the average cost of generation claimed by CSPGCL for
FY 2021-22 is substantially high, hence the purchase of power from Marwa TPP for
retail sale is inflating retail tariff. The actual Station Heat Rate and Auxiliary
Consumption is higher than the approved values and all such inefficiency is
increasing the cost of generation. The objector submitted that during FY 2021-22, the
PAF of Marwa TPP was only 54.67%, against the approved PAF of 76.5%. CSPGCL
has claimed capacity charges of Rs. 1513.78 crore as against the approval of Rs.
1526.18 Crore. The objector stated that based on the actual Plant Availability Factor
(PAF), CSPGCL has claimed an excess capacity charge of Rs. 423.11 crore. The
objector prayed for not allowing the excess capacity charges of Rs. 423.11 crore
during FY 2021-22.

Petitioner’s Reply
CSPGCL submitted that the CSERC Regulations provide specific mechanism for
dealing with under / over performance by any entity. CSPGCL in its true-up petition
has followed the Regulations without any deviation. The objector has pleaded for
circumventing the Regulations which is not acceptable.

Commission’s View
On account of lower actual PAF as compared to normative PAF, CSPGCL, in
accordance with the CSERC MYT Regulations, 2015, has claimed lower Fixed
Charges of ABVTPP. The Commission has also followed the CSERC MYT
Regulations, 2015 while approving fixed charges for FY 2021-22 considering sharing
of gains/losses, the details of which are provided in subsequent Chapter of this Order.

Landed Price and GCV of coal for Marwa TPP/ ABVTPP


Further, the objector stated that under Form 15B for Marwa TPP, CSPGCL has
submitted that landed price of coal is lower than the approved landed price and GCV
of coal is equal to the approved GCV. CSPGCL has recovered Rs. 57 Crore on
account of Fuel Cost Adjustment (FCA) from consumers of the State without any
increase in fuel cost.

CSERC Tariff Order FY 2023-24 5


The objector further requested not to load on retail consumers any under recovery (Rs.
172.91 crore) from sale of power to TSDISCOMs and prudently examine the FCA
and VCA charges determined by CSPGCL and CSPDCL before recovery from
consumers.

Petitioner’s Reply
CSPGCL submitted that the contentions of the objector are incorrect. Table 7-14 of
the Tariff Order for FY 2021-22 (Page 218) shows that at the time of Tariff Order, the
GCV of coal was considered as 3631 kcal/kg and the landed price of coal was
considered as Rs. 1990.87/MT. At the time of true up the uncontrollable parameters
such as GCV of coal and landed price of coal get substituted by the actual values
instead of the projected values. Therefore, in the format 15B, the actual GCV of coal
of 3470 kcal/kg has been considered. Similarly, the actual landed price of coal of Rs.
2272.04/MT has been considered. Further, as the actual transit loss was lower than the
normative, following the precedence set in the previous Tariff Orders, CSPGCL has
claimed actual landed price of coal at a lower value of Rs. 2270.61/MT. In view of the
above, CSPGCL requested the Commission that all the prayers made by the objector
may be rejected.

Commission’s View
The Commission has done prudence check on the submission of CSPGCL and has
accordingly approved the coal cost in line with the provisions of CSERC MYT
Regulations, 2015 and as per the settled methodology adopted in previous Tariff
Orders.

2.2.2 Cost of Coal


The Objector submitted that CSPGCL has not provided consolidated quantum and
cost of coal consumed, in its True-up Petition for FY 2021-22. Also, claim against
cost of coal and net generation in the True-up Petition are not matching with the
figures as per Audited Balance Sheet of FY 2021-22. The Objector requested the
Commission to direct CSPGCL to submit reconciled data in the True-up Petition for
FY 2021-22 to carry out proper True-up exercise.

Petitioner’s Reply
CSPGCL denied that there is any infirmity in claiming coal cost and net Generation.
CSPGCL submitted that the coal cost has been computed as per settled methodology
approved by the Commission in all previous Tariff Orders. While the accounting cost
is determined in accordance with moving average price of coal, for regulatory purpose
the rate is determined on the basis of replacement price (determined on the basis of
landed rate of the coal during the year). Further, in the regulatory computation, the
landed cost of coal includes all the costs incurred in transportation. In the financial
accounts, the cost incurred on employees, A&G and R&M of external CHP is part of
O&M cost and not the fuel cost. It is for this reason that for each plant the O&M cost
incurred on coal transportation is added in the landed cost computation and is
deducted from the O&M cost. CSPGCL also submitted that for determination of
landed cost of coal, all relevant data has been submitted along with the bimonthly
FCA calculations.

6 CSERC Tariff Order FY 2023-24


Regarding the difference in net generation in the accounts and in the True up Petition,
CSPGCL submitted that net generation in Accounts refer to the scheduled energy,
whereas net generation as per True up Petition refers to actual net generation. In
support of both the data, CSPGCL has already submitted the DSM statement certified
by CSLDC. CSPGCL submitted that in the last decade these issues have been dealt by
the Commission in number of cases and the regulatory practice has been consistent
for more than a decade. Therefore, the objection may also be considered barred by the
principle of res-judicata.

Commission’s View
The Commission has done prudence check on the submission of CSPGCL and has
accordingly approved the coal cost and net generation in line with the provisions of
CSERC MYT Regulations, 2015 and as per the settled methodology adopted in
previous Tariff Orders.

2.2.3 Operational Parameters for CSPGCL Thermal Plants


The Objector submitted that the PAF and other operational parameters for FY 2021-
22 for HTPS and Marwa TPP are lower than approved values. The Objector requested
the Commission to allow operational parameters of HTPS and Marwa TPP on the
basis of approved values without relaxing the normative values.

Petitioner’s Reply
CSPGCL submitted that it has considered normative operational parameters in
accordance to the Regulations and the undisputed Tariff Order for FY 2021-22. In the
instant True up Petition, no prayer for relaxation of the norms has been made.
CSPGCL also submitted that the appropriateness of the Regulations cannot be
challenged through the objection. Such pleadings do not sustain even in an Appeal
filed before the Hon‟ble APTEL. CSPGCL referred to the decision of the Hon‟ble
APTEL in the Appeal No. 5 of 2013 read with the decision of Constitution bench of
Hon‟ble Supreme court of India in PTC India Ltd. v/s CERC reported at 2010 (4)
SCC page 603, wherein the Hon‟ble Supreme Court has held that validity of the
Regulations framed under the Act can be challenged only by seeking judicial review
under article 226 of the constitution of India and not otherwise. In view of the above,
CSPGCL prayed to reject the objection and allow CSPGCL claim as prayed in the
True up Petition.

Commission’s View
The Commission has done prudence check on the submission of CSPGCL and has
accordingly approved the performance parameters and carried out sharing of gains
and losses in line with the provisions of the CSERC MYT Regulations, 2015 and as
per the settled methodology adopted in previous Tariff Orders.

2.2.4 Non-Tariff Income of CSPGCL


The Objector submitted that CSPGCL has claimed the Non-Tariff Income of Rs.
34.74 Crore for FY 2021-22, whereas as per the Audited Balance Sheet for FY 2021-
22, the Non-Tariff Income is Rs. 50.40 Crore. Therefore, the Commission should

CSERC Tariff Order FY 2023-24 7


consider the Non-Tariff Income of CSPGCL for FY 2020-21 as Rs.50.40 Crore and
prudently check revenue suppression of Rs.15.66 Crore.

Petitioner’s Reply
CSPGCL submitted that in the True up Petition, it has explained the principles
followed and specific exclusions made in Non-tariff Income. The approach and
methodology adopted by CSPGCL is in line with the settled principles and practice
adopted in previous Tariff Orders. Further, in the instant True up Petition, CSPGCL
has not claimed residual salvage value of KTPS plant of more than Rs. 61 Crore. The
cost of decommissioning has also not been claimed in the instant True up Petition. In
compliance to the principle adopted in the previous Tariff Orders, leave has been
craved for submission of detailed settlement of revenue from sale of scrap and
recovery of salvage value of plant / balance stores / cost of decommissioning etc. in
the True up for FY 2022-23. Further, as per well settled principle and practice, the
interest on FDRs pertaining to the coal blocks have been reduced from the Capital
cost of the projects and hence for the regulatory purpose they are not considered as
revenue income. Thus, all components of Non-tariff Income have been dealt in the
True up Petition in accordance to the Regulations and undisputed previous Tariff
Orders of the Commission. Hence, CSPGCL requested the Commission to allow Non-
Tariff Income as submitted in the True up Petition.

Commission’s View
The Commission has approved Non-Tariff Income for FY 2021-22 after due prudence
check and based on the approach adopted by the Commission in previous Tariff
Orders. The details are provided in subsequent Chapter of this Order.

2.2.5 Non Adjustment of Income Tax Refund by CSPGCL


The objector submitted that CSPGCL has received Income Tax refund of Rs. 69.48
Crore pertaining to AY 2020-21 ordered on 30.03.2021, but the same was not
adjusted in the True up of FY 2021-22. The Objector requested the Commission to
adjust Income Tax refund of Rs. 69.48 Crore pertaining to AY 2020-21 in the True up
of FY 2021-22.

Petitioner’s Reply
CSPGCL submitted that this specific issue has been clarified as part of additional
submission 1, vide Letter No. 35 dated 16.01.2023. In none of the previous years, for
CSPGCL, the ROE was grossed up by the tax rate. The tax was always allowed by the
Commission on actual basis. The income tax refund received during FY 2021-22
pertains to AY 2020-21 (FY 2019-20). In the FY 2019-20, the actual pre-paid tax was
Rs. 130.57 Crore, the actual income tax computed was Rs. 70.68 Crore and tax refund
of Rs. 59.89 Crore was claimed. In the True up for FY 2019-20 (dealt in the Tariff
Order for FY 2022-23), only the computed tax of Rs. 70.68 Crore was claimed and
allowed. In the true up of FY 2019-20, no claim was made / allowed for the claim of
Rs. 59.89 Crore. The said refund claim along with the applicable interest as per the
Finance Act materialized during the FY 2021-22. Copy of the challans, ITR and the
Refund order have been submitted to the Commission. As the above amount was
never considered as pass through by the Commission, hence no treatment of such

8 CSERC Tariff Order FY 2023-24


refund (including interest on the same) qualifies for adjustment during True up of
FY 2021-22.

Commission’s View
The Commission has approved Income Tax for FY 2021-22 after due prudence check
and based on the approach adopted by the Commission in previous Tariff Orders. The
details of income tax refund are provided in subsequent Chapter of this Order.

2.2.6 Depreciation for ABVTPS (Marwa) for FY 2021-22


The Objector submitted that it has entered into a PPA with CSPDCL for purchase of
power supplied by ABVTPS to CSPDCL. The Agreement is for 12 years and this
Agreement has been entered after negotiation between the two State Governments.
Ultimately the ARR approved for the project is passed on by CSPDCL to
TSDISCOMs. TSDISCOMs requested the Commission to consider their views and
objections before approval of ARR of ABVTPS. TSDISCOMs submitted that as per
Regulation 24 of Chhattisgarh State Electricity Regulatory Commission (Terms and
Conditions for determination of tariff according to Multi-Year Tariff principles and
Methodology and Procedure for determination of Expected revenue from Tariff and
Charges) Regulations, 2015, the depreciation rate is 5.1% and the amount of
depreciation estimated ought to be Rs. 447.86 Crore, whereas CSPGCL has claimed
the depreciation of Rs. 521.53 Crore, which works out to a rate of 5.94%. CSPGCL
has claimed higher depreciation in order to match its debt repayment obligation.
TSDISCOMs also stated that the PPA is not co-terminus with the life of the project.
The benefit out of advance depreciation charged on TSDISCOMs will accrue to the
beneficiary at later years. TSDISCOMs requested the Commission to consider the
applicable depreciation rate as per Regulations. The difference between the
depreciation claimed by CSPGCL i.e., Rs. 521.53 Crore and Rs. 447.86 Crore may be
to the account of beneficiary (CSPDCL) after 13th year and after the expiry of PPA
with TSDISCOMs.

Petitioner’s Reply
CSPGCL reiterated its submission with respect to locus of TSPCC or TSDISCOMs to
file objection against CSPGCL True up Petition for FY 2021-22. In addition,
CSPGCL submitted that as per the definition given in the Act (Section 2 (15)),
TSPCC is not a consumer of CSPDCL. The jurisdiction of the Commission is limited
to the state of Chhattisgarh and as such TSPCC has no locus to participate in the
proceedings before the Commission.
Without prejudice to the above, CSPGCL submitted that it is a settled legal position
that any agreement between two parties cannot override the specific provisions of the
Regulations. CSPGCL has prayed for allowing the depreciation for ABVTPS
(Marwa) in accordance to the last proviso of the Regulation 24.4 of the Regulations,
2015. The appropriateness of the Regulations cannot be challenged through objection.
Such pleadings do not sustain even in through an Appeal before the Hon‟ble APTEL.
CSPGCL referred to the decision of the Hon‟ble APTEL in the Appeal No. 5 of 2013
read with the decision of Constitution bench of the Hon‟ble Supreme Court of India in
PTC India Ltd. v/s CERC reported at 2010 (4) SCC page 603, wherein the Hon‟ble
Supreme Court has held that validity of the Regulations framed under the Act can be
challenged only by seeking judicial review under article 226 of the constitution of
CSERC Tariff Order FY 2023-24 9
India and not otherwise. As the pleadings of the Objector are contrary to the
established principles of law, it is submitted that the Objection deserve to be
summarily dismissed.
Further, it is also a well settled legal position that at the time of true up the principles
followed at the time of tariff determination are applicable. The tariff for FY 2021-22,
was determined by the Commission vide Order dated August 2, 2021 read with
detailed Order dated August 11, 2021 on the Petition No. 09 of 2021(T). The
depreciation for ABVTPS was approved by the Commission vide para 7.6.3, page
223-225 in the Tariff Order. The aforesaid Order has attained finality and therefore
lays down binding principle for the purpose of True up. In view of the above
CSPGCL requested that the objection raised by TSPCC or TSDISCOMs may be
rejected on the ground of merits too.

Commission’s View
The Commission while approving the ARR for FY 2021-22 in the Order dated August
11, 2021 on the Petition No. 09 of 2021(T) had approved the depreciation in
accordance with the provision specified in Regulation 24.4 of the CSERC MYT
Regulations, 2015. Therefore, at the true up stage, the Commission has followed the
same principles as detailed in subsequent chapter of this Order.

2.3 Objections on CSPTCL’s petition


2.3.1 Transmission Losses and Short-Term Open Access (STOA) Charges
The objector submitted that STOA charges proposed by CSPTCL are 36.05 paise per
unit for FY 2023-24. These charges proposed by CSPTCL are on the higher side as
compared to other States. The objector cited the example of Himachal Pradesh, Goa,
Uttarakhand, Jharkhand, Uttar Pradesh, Odisha and Telangana wherein Transmission
Charges are much lower as compared to Chhattisgarh. Therefore, the Objector
requested the Commission to rationalise the Transmission Charges of CSPTCL at
least at par with Transmission Charges of Odisha, which is 28.00 paise per unit
(highest among these States).

Petitioner’s Reply
CSPTCL submitted that STOA charges proposed for FY 2023-24 in the Petition are
based on the methodology adopted for determination of STOA charges in the previous
Tariff Orders.

Commission’s View
The Commission has approved the STOA Charges based on the methodology adopted
in the past Tariff Orders. The detailed computation has been given in relevant Chapter
of this Order.

2.4 Objections on CSLDC’s petition


2.4.1 SLDC Operating Charges
The Objector submitted that CSLDC is currently charging Operating Charges at Rs.
2000 per day per transaction for all inter-State as well as intra-State Open Access
consumers, which is very high. The Objector cited examples of States like Delhi,

10 CSERC Tariff Order FY 2023-24


Madhya Pradesh, Haryana, Uttar Pradesh, Gujarat and Goa, wherein these charges are
Rs. 1000 per transaction per day. The Objector requested the Commission to reduce
the Operating Charges and make it at par with other States.

Petitioner’s Reply
CSLDC submitted that in the Western Region, SLDC Operating Charges in
Maharashtra and Madhya Pradesh are Rs. 2,250 per day and Rs. 3,000 per day,
respectively. Thus, SLDC Operating Charges of Rs. 2000 per day levied by CLSDC is
justifiable in comparison of SLDC operating charges levied in Maharashtra and
Madhya Pradesh.

Commission’s View
SLDC Operating Charges for STOA consumers are reasonable and have been retained
at existing levels.

2.5 Objections on CSPDCL’s petition


2.5.1 Telecom Services in Industrial Tariff Category
The Airtel Telecom, Cellular Operators Association of India (COAI), Digital
Infrastructure Providers Association (DIPA) and Jio Digital Life submitted that the
telecom industry is being charged commercial rates as against industrial rates,
resulting in undue financial burden on the telecom industry which works round the
clock like any other industry. As a result, early deployment of 5G in the States will
lead to multiple new sources of revenue generation for local bodies, State
Governments, Start-ups, existing businesses, and most importantly, benefits for the
citizens. Telecom sites should be provided electricity connection under Utility
/Industrial tariff. SERCs may be requested to incorporate the same in their tariff
orders.
We request that in the State EB Tariff Orders, Telecom Industry electricity tariff may
kindly be placed under Industrial rates rather than the commercial rates.

Petitioner’s Reply
CSPDCL submitted that no activity of manufacturing is being carried-out in the
telecom towers thus present classification in the non-domestic category is appropriate
and same should be continued.
Further it has submitted that designing and re-structuring of retail supply tariff is
statutory function of State Commission under Electricity Act. Hence, applicant‟s
request can only be considered subject to protection of CSPDCL‟s approved ARR for
the year FY 2023-24.

Commission’s View
The Commission found that the present tariff categorisation of the objector is
appropriate, thus, the tariff category of the objector kept unchanged.

2.5.2 Rationalize the Transmission Loss


The objector submitted that the inter-state and intra state transmission losses proposed
by CSPDCL are 3.43% and 3% respectively, which are on very much higher side as

CSERC Tariff Order FY 2023-24 11


compared to the other states. The Objector citied the examples of Himachal Pradesh,
Uttarakhand, Jharkhand and Madhya Pradesh wherein Transmission Losses are much
lower as compared to Chhattisgarh. Therefore, the Objector requested the
Commission to rationalise the Transmission Losses of CSPDCL for the Control
Period at least at par with Transmission Losses of Madhya Pradesh, which is 2.62%
(highest among these States).

Petitioner’s Reply
CSPDCL submitted that based on transmission loss achieved for FY 2020-21
(3.00%), the Commission has set target as 3.00% every year of the Control Period
from FY 2021-22 to FY 2023-24. CSPDCL considered intra state transmission losses
as determined in the latest Tariff Order dated 13.04.2022 and inter-state transmission
losses has been considered as weighted average transmission losses of actual 12
months of Western Region.

Commission’s View
The Commission approves the transmission loss considering the data submitted by
CSPTCL and hence, comparing the transmission loss of Chhattisgarh with other
States has no relevance.

2.5.3 Parallel Operation Charges


The Objector submitted that the CSPDCL‟s prevailing POC charges is 13 paisa/kWh
and thus, requested the Commission to consider the POC charges payable by CPP to
CSPDCL for its captive and non-captive load as 10 paisa/kWh.
Another Objector submitted that parallel operation charges were increased up to
300% only on the request of CSPDCL to fulfil the revenue gap without considering
any exercise before hike. Now CSPDCL is getting revenue surplus, hence a part of
this surplus may be used to reduce the existing Parallel operation charges by 50%
from existing tariff.

Petitioner’s Reply
CSPDCL submitted that POC charges are constituent of non-tariff income and any
rationalization among such constituents would have a bearing on tariff of normal
electricity consumers. We requested to continue the existing methodology for
calculation of Parallel Operating Charges.

Commission’s View
The Commission has found the present POC charges appropriate, hence, do not
require any change.

2.5.4 Reactive Energy Charges


The objector submitted that the CSPDCL‟s reactive energy charges is 27 paisa/kWh
which is on higher side and hence, requested the Commission to consider the reactive
energy charges as 20 paisa/kWh.

12 CSERC Tariff Order FY 2023-24


Petitioner’s Reply
CSPDCL submitted that based on past Tariff Order, Reactive Energy Charge has been
considered by the Commission @ 27 paise per unit and the same shall be continued.

Commission’s View
The Commission has found the present Reactive Energy Charges appropriate, hence
the request of the objector is not accepted.

2.5.5 Non-Reconciliation of data


The Objector submitted that CSPDCL has submitted Tariff Petition in December
2022 and it has revised lot of data vide additional submission. The additional
submission is meant to supplement data gap, which was submitted originally. In fact,
CSPDCL has amended the Tariff Petition without filing amended Petition and
requisite affidavit, which is not permissible under the Law.
CSPDCL has submitted Audited Balance Sheet for FY 2021-22; however, no
reconciliation has been provided in support of submission made under additional
submission and there remain several ambiguities and discrepancies of data.
The Objector submitted that due to such different sets of data for FY 2021-22, it is
impossible for stakeholders to make any legitimate objection on present Tariff
Petition filed by CSPDCL. Therefore, the Commission should direct CSPDCL to
amend the Tariff Petition and to submit reconciled data in order to enable
stakeholders/consumers to make legitimate suggestions/ objections.

Petitioner’s Reply
As regards objection on difference between the Tariff Petition and Additional
Submission, CSPDCL submitted that the contention of the Objector that the data is
non-reconciled is wrong.
Pursuant to the directions of the Commission, during Technical Validation Session
(TVS) the Petitioner has submitted the item-wise reconciliation of the data submitted
with the Audited Balance Sheet.

Commission’s View
The CSPDCL has asked to remove the discrepancies in data submitted with the
petition and the same was compiled by CSPDCL.

2.5.6 Issues related to Agriculture Consumption


The Objector submitted that based on analysis of actual sales to Agriculture
consumers from FY 2016-17, the sales forecast for Agriculture consumers during FY
2023-24 as submitted by CSPDCL appears to be on higher side (245 units/HP/month)
against that claimed by CSPDCL in True-up for FY 2021-22 (238 units/HP/month).
CSPDCL has shown Agriculture consumption during FY 2021-22 lower than FY
2020-21 even when number of such consumers is projected to increase considerably,
which shows absence of realistic and reliable data and estimation.

CSERC Tariff Order FY 2023-24 13


Existing Energy Charges for Agriculture category is Rs.5.05 per unit whereas
CSPDCL has proposed lower consumption of Agriculture Pumps during FY 2022-23
and also proposed to dispose surplus power at a lower rate, creating an artificial loss.
From the above, it is quite clear that CSPDCL has projected lower consumption of
Agriculture Pumps during FY 2022-23 in order to show lower revenue artificially.
Energy Meters of Agriculture Pumps are not read regularly and lakhs of such
connections are served without any meter in violation of Electricity Act, 2003, hence,
it has become quite difficult to determine their actual consumption.
The Objector submitted that the report of the study on Agricultural consumption as
directed in Tariff Order for FY 2017-18, FY 2018-19 and FY 2019-20 should be
made available along with Tariff Order for FY 2023-24. Action taken report to curb
the large number of defective energy meters and present status of such meters as
observed under Tariff Order for FY 2018-19 and FY 2019-20 should also be made
available along with Tariff Order for FY 2023-24.
The Objector submitted that a Suo-Motu Petition should be filed in matters relating to
Agriculture category, viz., their actual consumption, issue of defective meters, un-
metered supply, assessment of consumption, etc. The Objector requested the
Commission to approve actual sales during FY 2021-22 and FY 2023-24 on the basis
of realistic data.

Petitioner’s Reply
CSPDCL submitted that it has submitted the justification for consumption of LV-3
category in revenue statement for FY 2021-22, in reply to data gaps dated January 25,
2023. Further, basis of projections of consumption for FY 2023-24 is detailed at Para
8.4 to 8.12 of the Tariff Petition.
CSPDCL submitted that the sales considered under agricultural category is taken from
its revenue statement (R-15) for FY 2021-22. The sales considered in true up part are
extracts of revenue statement, which is based on meter readings/assessments as per
the provisions of Supply Code. The difficulties in replacement of stopped and
defective meters such as diversity in locations of agriculture pump and BPL
consumers, prolonged locked premises are prominent reasons for existing status.
All other issues such as Suo-motu Petition in the matters of agriculture category, etc.,
with regard to LV-3 category are not connected to CSPDCL‟s Tariff Petition, hence,
no comments are offered.

Commission’s View
The Commission has verified the sales to the agricultural category for FY 2021-22,
based on the R-15 submitted by CSPDCL, and the same has been considered in the
true-up for FY 2021-22. The Commission has already issued directions to CSPDCL
for improvement of its agricultural metering. Further, in line with the approach
adopted in the previous Order, the Commission has considered notional revenue from
sale to agricultural category for FY 2021-22, based on the approved ABR and the
sales reported by CSPDCL. The methodology adopted by the Commission for
projecting the sales to the agriculture category for FY 2022-23 to FY 2024-25 has
been elaborated in the relevant Chapter of this Order.

14 CSERC Tariff Order FY 2023-24


2.5.7 UDAY Scheme and Distribution Losses
The Objector submitted that CSPDCL has committed to specific loss levels under
UDAY Scheme vide MoU executed on January 25, 2016.
Previously, CSPDCL had claimed share of gains on reduction of Distribution Losses
during FY 2016-17 in Provisional True-up Petition; however, the same was rejected
by the Commission in the Tariff Order for FY 2018-19.
From the 1st Amendment in CSERC MYT Regulations, 2015 effective from April 1,
2016, it is amply clear that the energy loss trajectory agreed and committed in writing
by CSPDCL shall prevail over provisions made in principal Regulations. Further,
CSERC MYT Regulations, 2015 specifies Transmission & Distribution Loss as
Controllable factor under Regulation 11.2 and provides mechanism for sharing of
under-achievement of stipulated targets.
CSPDCL has reported Distribution Loss of 16.14% including EHV sales during FY
2021-22. Surprisingly, without attaining prescribed target of 14.64% for FY 2018-19.
Further, the share of loss of Rs. 131.50 Crore computed by CSPDCL is not accounted
in ARR for FY 2021-22, which is unacceptable.
Considering all above reasons and provisions of CSERC MYT Regulations, 2015 and
UDAY Scheme, the Objector requested the Commission:
a. to stipulate the Distribution Loss including EHV Sale at 14.22% as approved by
the Commission for FY 2021-22.
b. to order for share of loss against non-achievement of Distribution/AT&C Losses
in accordance with CSERC MYT Regulations, 2015.
c. to direct CSPDCL for reconciliation of quantum of Net Power Purchase with
quantum of Energy available at Distribution Periphery.
d. to consider the distribution loss trajectory committed by CSPDCL under
Revamped Distribution Sector Scheme in the True-up and Tariff Order.

Petitioner’s Reply
The Petitioner submitted that it has clarified the reasons for not considering
deductions due to under achievement of line loss targets at 33 kV level at Para 6.13
and Para 6.14 of the Tariff Petition. This includes the modified table on sharing of
efficiency losses. The request of Objector to substitute 33 kV distribution loss with
AT&C losses is strongly objected as it considers collection efficiency too. As the
collection efficiency is not included as a performance parameter for distribution
licensee, consideration of AT&C losses at 33 kV level would be against the
Regulations.
The Objector has not considered the differential timings involved in billing cycles of
power purchase and consumers. CSPDCL bills more than 60 lakh consumers in LT
spread across the State and it is difficult to issue simultaneous bills to all consumers at
one time due to constraints in meter reading, while the power purchase bills observe
definite monthly cycle.
Further CSPDCL has also provided the details of Quantum of net power purchase
with the energy available while showing the statement of Energy balance along with
the tariff Petition.

CSERC Tariff Order FY 2023-24 15


The Petitioner would further like to submit that the distribution loss trajectory as
projected by the petitioner is in accordance with the Distribution loss trajectory as
approved by the Commission.

Commission’s View
For true-up for FY 2021-22, the Commission has considered the Distribution Losses
based on actual energy sales and purchase with respect to the Distribution Losses
approved in the Tariff Order for FY 2021-22. Further, the efficiency losses on account
of non-achievement of the distribution loss trajectory approved in the Tariff Order,
despite inclusion of assessed sales, has been computed and shared between CSPDCL
and the consumers, in accordance with the CSERC MYT Regulations, 2015. For the
Control Period, the Commission has approved the trajectory for reduction of
Distribution Losses as detailed in relevant Chapter of this Order. The power purchase
quantum has been matched with the energy requirement as per the approved Energy
Balance. The detailed approach of the Commission is discussed in relevant Chapter of
this Order.

2.5.8 Higher Cost of Renewable Power and Lower Quantum of Concessional Power
Purchase
The Objector submitted that CSPDCL has purchased Renewable Power at quite
higher cost and much lower quantum of concessional power than approved, which
indicates effort to inflate over-all power purchase cost. CSPDCL has not explained
the reasons for such variations, which are causing additional burden to the consumers
of approx. Rs. 293 Crore for FY 2021-22.
The Objector also submitted that the information provided in the present Petition and
additional information do not match with the Audited Accounts for FY 2021-22.
CSPDCL has entered into an Agreement with SECI for purchase of Solar power of
2373 MW at very low rate of Rs. 2.57 per unit. Hence, such high purchase cost of
Solar power during FY 2023-24 @3.79 is not understandable and it needs prudent
examination.
Further, CSPDCL has proposed not to draw any power from Renewable Generation
from Biomass during FY 2023-24 and on the other hand, CSPDCL is drawing less
power from some Central Generating Stations of NTPC against the allocated capacity
and the resultant cost of power from such plants is very high.
Therefore, not drawing power from State Biomass Renewable Generators and buying
from outside of the State at higher rates is not a justifiable and wise proposal as State
Biomass Renewable Generators also contribute towards employment, utilization of
waste biomass, support to Agriculture and Agro-based Industries, Environment
Protection, Electricity Duty and other taxes etc. Notably, such proposal was turned
down by the Commission in Tariff Order FY2022-23.
Hence, the Objector is requesting the Commission to:
 prudently examine the inconsistent data supplied by CSPDCL in Tariff
Petition, Additional Submission/s and VCA Calculations
 prudently examine the cost of Renewable and Concessional Power during
FY2021-22 and FY2023-24

16 CSERC Tariff Order FY 2023-24


 continue buying power from State Biomass Renewable Generators during
FY2023-24
 seriously examine the ways to come out of unnecessary, un-required and
costly power purchase agreement/ allocation from CGS.

Petitioner’s Reply
CSPDCL submitted that the procurement of renewable energy power is to meet the
RPO target. Further, the power purchase is made in accordance with the long-term
Power Purchase Agreement (PPA) at tariff determined/approved by the Commission.
Hence, the objection that RE purchase has been done at higher cost is denied. The
Objector has not taken into consideration the additional billing of DSM and statutory
taxes and duties applicable to biomass sources. Further, the reduced rates in respect of
solar purchase is due to availability of cheaper power during FY 2021-22, thereby,
reducing the effective average weighted rate. The procurement of hydel/other RE
contains sources with less than installed capacity 25 MW. The per unit rates approved
for small hydel plants varies between Rs. 6.15 to Rs. 7.74 per unit (levelised tariff)
plus taxes, duties and water charges for FY 2021-22. CSPDCL has submitted source-
wise power procurement details in MS Excel format along with the Petition as well as
in reply to additional points under prudence check.
In view of the above, CSPDCL requested to dismiss the prayers made by the
Objector.

Commission’s View
The Commission has considered the quantum and rate of purchase from RE sources
and Concessional Power sources for FY 2021-22, as elaborated in relevant Chapter of
this Order. The Commission has considered the quantum and rate of purchase from
RE sources and Concessional Power sources for the Control Period, as elaborated in
the relevant Chapter of this Order.

2.5.9 Banking of Power


The Objector submitted that the „Banking of Power‟ is a recent development in the
field of Distribution Business. Banking of energy does not involve any purchase of
electricity. It is a cashless transaction and is a facility available to Distribution
Licensee like storing energy with other Discoms for subsequent own consumption.
The Banking is done between two Discoms on mutually agreed terms and conditions.
This methodology is mutually beneficial as one Discom can bank its costly surplus
power with other Discom, without surrendering at quite low UI Rates in the Grid, and
can avail back such power in the hours of shortages, avoiding emergency purchase of
costly power. This methodology facilitates discipline in operation of the Grid,
Distribution network and Power Purchase Cost.
In the present True-up Petition for FY2021-22, CSPDCL has neither shown any
reason for not returning 437.94 MU of power banked with it in totality although it had
surplus availability of power nor has it submitted the “Power Banking Pass Book. It is
clear that the quantum of such Banked Power is quite high and is purchased in one
year and used/sold in later years or vice-versa. Amount of such power may be as high
as Rs.500 Crore to Rs.1,000 Crore evaluated at Average Power Purchase Cost.

CSERC Tariff Order FY 2023-24 17


The Objector submitted that the Judgment of Hon‟ble APTEL dated July 1, 2014 in
Appeal No. 220 of 2013 (Himalaya Power Producers Association Vs. HPERC, etc.) is
related to the determination of Average Pooled Power Purchase Cost (APPC) under
REC mechanism, hence, the directives of Hon‟ble APTEL should not be taken in
other context.
If the quantum and cost of such Banked Power is not accounted in the same Financial
Year, it may create several problems relating to accounting and statutory lapses, viz:
a. Banked Power is Stock in Hand (positive or negative, as the case may be) and it
should be accounted in the Balance Sheet and Profit/Loss Account of CSPDCL.
b. By not accounting the quantum and cost of such Banked Power in the same
financial year, Revenue Surplus or Deficit may be siphoned to the coming years,
which will create artificial stand-alone Profit/Loss for that particular Financial
Year.
c. It is against the basic principles of accounting and Accounting Standards being
followed.
d. It is against the statutory provisions of Income Tax.
CSPDCL has failed to comply with the above directives of the Commission while
filing True-up Petition for FY 2021-22. In view of the above, the Objector submitted
following:
a. Such quantum of Banked Power should be treated as Stock in Hand (positive or
negative, as the case may be) and Cost of such Banked Power should be
accounted in the same Financial Year. Further, CSPDCL should be directed to
comply with the directive already issued to maintain a „Power Banking Passbook‟
having details like Banking Partner/s, Banked Quantum, Date & Time of such
Banked Quantity, effective UI Rates on such time, Agreed Date and Time for
Reverse Banking, etc.
b. Necessary Regulations be made at the earliest with respect to Banking of Power
as announced in Tariff Order for FY 2019-20.
c. Trued-up details from FY 14-15 are showing a Returnable Quantum of
437.94MU in Power Banking whereas CSPDCL is reporting Receivable Quantum
of 328.92 MU at the end of FY21-22 which needs to be examined prudently.
d. Discrepancy in the data submitted by CSPDCL in the True-up Petition and
Additional Submission needs to be examined prudently.

Petitioner’s Reply
CSPDCL submitted that it is complying with the directions issued by the Commission
at Para 10.2(vi) „New directives to CSPDCL‟ regarding banking transactions. Further,
CSPDCL has also submitted the details showing reconciliation of banking
transactions during FY 2021-22 with respect to corresponding banking agreements
showing energy units received and unit returned in reply to Query No. 25 of Letter
No. 2626, dated February 3, 2023. The aforesaid replies were also placed in public
domain.
The contentions of banking about previous many years is not a subject matter of
present Petition when the Commission has already settled the transactions in terms of

18 CSERC Tariff Order FY 2023-24


true-up Orders for each of the previous year. The Commission has approved final true
up to FY 2020-21.
In view of the above, the Objector‟s prayer is ineffective; hence, may be dismissed.

Commission’s View
While undertaking the final true-up for FY 2021-22, the Commission sought all
relevant details of banking of power and has approved the quantum of banked power
after due prudence check, as elaborated in the relevant Chapter of this Order.

2.5.10 Review of Final True-up of FY 2018-19


The Objector submitted that in the present Tariff Petition, CSPDCL has sought review
of Tariff Order for FY 2022-23 pertaining to true-up of FY 2018-19. This Review
Petition was filed for an additional claim of Rs. 518.03 Crore against approved true-
up for FY 2018-19 under Tariff Order for FY 2022-23. Public Notice issued by the
Commission and CSPDCL in the newspaper/s inviting comments, suggestions and
objections from the public do not mention about the Review of Tariff Order for FY
2022-23 within the scope of present Petition. Since comments/objections are not
called on review of Tariff Order for FY 2022-23 pertaining to True-up for FY 2018-
19, it would neither be legitimate for the public/stakeholders to raise any objection/s
on the merits of such a huge demand of Rs.518.03 Crore (including carrying cost) nor
for the Commission to address this issue without having followed proper procedure.
Therefore, the Objector requested the Commission not to re-review the matters of FY
2018-19 which is already time-barred and which has nature of appeal, to disallow
claim of Rs. 518.03 Crore under ARR for FY 2023-24 and to issue Public Notice for
the review of Tariff Order for FY 2022-23 inviting suggestions/ objections from the
public/ stakeholders and calling for a Public Hearing on the matter.

Petitioner’s Reply
CSPDCL submitted that the prayer made by the Objector does not hold good in light
of the directions of the Commission to include the points of review of Tariff Order
dated August 2, 2021 in ensuing Tariff Petition for FY 2023-24. Accordingly,
inclusion of Chapter 5 under present Petition is in pursuance to the Order dated
August 5, 2022 in Review Petition No. 51 of 2022 read with provisions of Order 47
Rule 1 of Civil Procedure Code.

Commission’s View
The reply of the Petitioner is self-explanatory.

2.5.11 Difference in Energy Sold and Actual Revenue Receipts from Retail Sale
The Objector submitted that revenue receipts claimed in the True-up Petition for FY
2021-22 is less than Revenue reported in R-15 format by CSPDCL, amounting to Rs.
54.44 Crore.
Similarly, CSPDCL has shown lower revenue from retail sale to LV3-Agriculture
category, amounting to Rs. 422.32 Crore.
The Objector submitted that in accordance with Section 45 of the Act, CSPDCL is
bound to recover energy charge as prescribed by the Commission under prevailing

CSERC Tariff Order FY 2023-24 19


Tariff Order and it cannot show any undue preference to a consumer or class of
consumers.
While truing-up of earlier years, the Commission has considered „additional revenue
for Agriculture metered category‟. During FY 2017-18, such additional revenue was
Rs. 351.24 Crore whereas during FY 2018-19, it is considered as Rs. 382.85 Crore
under true-up.
Therefore, the Objector requested the Commission to:
a. prudently check shortage of revenue of Rs. 54.44 Crore received from retail sale
of power to HT Consumers during FY 2021-22 in light of R-15 data provided by
CSPDCL
b. consider additional revenue of Rs.422.32 Crore from sale of power to LV-3
Agriculture category during FY 2021-22 in accordance with prescribed Energy
Charges under prevailing Tariff Order and the approach followed by the
Commission in previous Tariff Order/s.

Petitioner’s Reply
CSPDCL submitted that the contentions about difference of Rs. 54.44 Crore are
baseless. CSPDCL has considered revenue reported in the audited accounts, under
„Revenue from sale of power‟ and „Non-Tariff Income‟ in Tariff Petition as per the
practice adopted by the Commission. Billing of Parallel Operation Charges, meter
rent, cross subsidy surcharge, etc., forms miscellaneous part of revenue and is
included under Non-Tariff Income. Therefore, comparing R-15 with figures of
audited balance sheet is superfluous.

Commission’s View
The Commission has performed prudence check on the revenue recovered from
consumers and has only considered the revenue reflected in Audited Accounts.
Further, in line with previous Tariff Orders, the Commission has addressed the issue
of additional notional revenue from LV-3 Category Consumers in the relevant
Chapter of this Order.

2.5.12 Discrepancy in Quantum & Cost of Power Purchased & Transmission Charges
The Objector submitted that the net generation by CSPGCL for FY 2021-22 differs
from quantum of power purchased by CSPDCL although entire power is purchased by
CSPDCL. Also, there is difference in the cost of power purchased from CSPGCL
during FY 2021-22.
Further, rebate of 2.5% is provided for timely payment against power purchase from
Central Sector; however, CSPDCL is not availing this benefit although sufficient
provision for working capital requirement is provided in the ARR. Thus, consumers
of the State are deprived from huge benefit of Rs. 219.38 Crore in the form of rebate
from CGS
Therefore, the Objector requested the Commission to:
a. prudently examine cost and quantum of power purchase as claimed by CSPDCL
during FY21-22.

20 CSERC Tariff Order FY 2023-24


b. allow rebate of Rs.147.55 Crore for FY 2021-22 and Rs.127.03 Crore for FY
2023-24 for purchase from Central Generating Stations and not to allow any
Delayed Payment Surcharge under ARR.

Petitioner’s Reply
The contentions on rebate from CGS are hypothetical in nature. The benefit of early
payment is consequential of discharging payment liability within the prescribed
timelines. This is in turn connected to the financial position of the Petitioner. As there
is no actual benefit received by the Petitioner towards early payment, the request of
Objector to consider rebate is ridiculous.

Commission’s View
The Commission has verified the reconciliation given by CSPDCL and CSPGCL and
has accordingly approved the quantum and cost of power purchased from CSPGCL in
the final true-up for FY 2021-22.
The Commission does not find any merit in the suggestion for considering notional
rebate on power purchase, which has not been received by the Petitioner, in the true-
up for FY 2021-22.

2.5.13 Non-compliance of Regulations in the matter of Recovery of VCA Charges


The Objector submitted that CSPDCL is not showing VCA Charges billed/recovered
to the consumers separately in the books of Accounts although LT R-15 shows it
separately but again HT R-15, VCA Charges are not shown separately. This is non-
compliance of MYT Regulations‟ 2015.
VCA Charges have gone as high as Rs 1.10 per kWh, increasing the tariff
substantially beyond Tariff Estimation because of which Power Intensive Consumers
like Mini Steel Plants are highly affected. Hence resetting of VCA Charges to “Zero”
in the Tariff Order is necessary so that Retail Tariff may become stable and
predictable as desired under National Tariff Policy.
Govt of India has notified Electricity (Amendment) Rules 2022 on 29.12.2022,
providing speedy recovery of variation of Power Purchase Costs of Distribution
Licensee through VCA Charges and to carry separate True-up for such VCA Charges
for any financial year to be completed by 30th June of the next financial year.
Therefore, the Objector requested the Commission to:
a. set VCA Charges to “Zero” at the start of FY23-24 for a stable and predictable
Retail Tariff
b. device mechanism for speedy recovery of VCA Charges
c. institute separate True-up mechanism for VCA and FCA Charges

Petitioner’s Reply
CSPDCL submitted that the contentions and prayers made by the Objector are absurd.
It is because the Objector has compared unlike with likes. The expenditure taken as
difference of power purchase cost (CHPP) on bi-monthly basis under the FCA and
VCA mechanism observes separate annual cycle specified at Regulation 67.8 of
CSERC MYT Regulations, 2015. Further, the expenditure taken as cost of power

CSERC Tariff Order FY 2023-24 21


purchase observes annual cycle of financial year. This different billing cycles give
rise to aforesaid difference. Hence, the contention of excess recovery through VCA is
incorrect.

Commission’s View
The Commission has verified the details provided by CSPDCL and has accordingly
approved the quantum and cost of power purchased from CGS stations in the final
true-up for FY 2021-22.
The approach adopted by the Commission for projecting quantum and cost of power
purchase from CGS stations for the Control Period is detailed in the relevant Chapter
of this Order. The Commission has also made certain modifications in the FCA and
VCA mechanism from FY 2023-24 onwards, as elaborated in the Tariff Schedule and
in the relevant Chapter of this Order.

2.5.14 Discrepancy in Quantum & Cost of Power Purchased from CSPGCL


The Objector submitted that that during FY 2020-21, net generation by CSPGCL
differs from quantum of power purchased by CSPDCL although entire power is
purchased by CSPDCL.
Therefore, the Objector requested the Commission to:
a. Prudently examine quantum of power purchase from CSPGCL against such
power claimed by CSPDCL during FY 2021-22 as there is multiplicity of data;
b. Prudently examine quantum of power purchase from Hasdeo Bango Hydel Power
Station of 403.35 MU as there appears to be no provision under True-up Petition
for FY 2021-22;
c. Prudently examine the cost of power purchase from CSPGCL claimed by
CSPDCL in FY 2021-22 as there is multiplicity of data.

Petitioner’s Reply
CSPDCL submitted that it has furnished the reconciliation of Power purchase cost and
Quantum as considered by the CSPDCL with CSPGCL in reply to the data gaps dated
23.01.2023 & dated 03.02.2023.

Commission’s View
The Commission has verified the details provided by CSPDCL and has accordingly
approved the quantum and cost of power purchased from CGS stations in the final
true-up for FY 2021-22.

2.5.15 Burden of Short Recovery of Power Cost of Marwa TPP on Retail Consumers &
Excess Recovery of Capacity Charges
The Objector submitted that CSPDCL has an agreement with Telangana for back-to-
back supply of power generated by Marwa TPP after adding trading margin of 7 paise
per unit. The average cost of generation claimed by CSPGCL during FY 2021-22 is
substantially high, hence, purchase of power from Marwa TPP for Retail Sale is
inflating Retail Tariff. Station Heat Rate is reported to be 2572.42 kCal/kWh against
approved 2372.42 kCal/kWh, meaning that coal consumption is higher to generate 1

22 CSERC Tariff Order FY 2023-24


unit of electricity. Further, the Auxiliary Consumption is also higher at 6.12% against
approved 5.25%. All such inefficiency is increasing the cost of generation. This is not
acceptable.
During FY 2020-21, PAF of Marwa TPP was only 55.06% against approved PAF of
76.5%. Similarly, during FY2021-22, PAF of Marwa TPP was only 54.67% against
approved PAF of 76.5% but CSPGCL has claimed Rs.1,513.78 Crore as Capacity
Charges against approval of Rs.1,526.18 Crore which is not reasonable. This means
that without running the plant to normative capacity, CSPGCL is recovering its fixed
cost from the consumers of the State, even when such plant is meant to supply
electricity to Telangana on back-to-back basis.
Further, CSPGCL has submitted under Form 15B for Marwa TPP that landed price of
coal is lower than approved and GCV of coal is also equal to approved but CSPGCL
has recovered Rs. 57 Crore on account of Fuel Cost Adjustment (FCA) from
consumers of the State, understandably without any such increase in Fuel Cost.
Therefore, the Objector requested the Commission to:
a. Consider ARR/ capacity charge of Marwa TPP on reduced PAF/PLF and
disallow excess claim of Capacity Charges of Rs. 423.11 Crore during
FY2201-22;
b. not to load on Retail Consumers any under-recovery from sale of power to
Telangana below the cost of generation amounting more than Rs. 172.91
Crore;
c. prudently examine the FCA and VCA charges determined by CSPGCL and
CSPDCL before recovery from consumers

Petitioner’s Reply
CSPDCL submitted that it is supplying power purchase from ABVTPP (Marwa) to
Telangana DISCOMs under back-to-back arrangement. It has been reiterated that
based on demand supply gap of the State, a portion of availability from Marwa is
utilised for supply to consumers of the State. CSPDCL submitted that out of total
availability of 4846.14 MU, the sale to Telangana is 1631.25 MU. Resultantly, the
short-dispatch to Telangana is utilised for supply to consumers of the State. Therefore,
the prayer submitted by the Objector is irrelevant and liable to be dismissed.

Commission’s View
The Commission has verified the details provided by CSPDCL and has accordingly
approved the quantum and cost of power purchased from CGS stations, including
ABVTPP, in the final true-up for FY 2021-22. Further, the recovery of Fixed Charges
by ABVTPP has been allowed in accordance with the CSERC MYT Regulations,
2015, as elaborated in the relevant Chapter of this Order. For true-up, the Commission
has approved sale of surplus power to Telangana after due prudence check, as detailed
in the relevant Chapter of this Order.

CSERC Tariff Order FY 2023-24 23


2.5.16 Preparation of R-15 and Status of Defective Meters and Assessed Billing
The data submitted in LT R-15 report from FY 2015-16 to FY 2022-23 (8 months)
along with Tariff Petition for FY 2022-23 shows that the number of defective meters
and assessed billing cases are extremely high.
Thus, it is quite evident that CSPDCL is not sure about actual energy consumption
and in large number of cases, billing is done on assessment basis. Hence, it is also
obvious that meter reading is not done on regular basis. Number of defective meters
are increasing in spite of several directives and Orders from the Commission.
CSPDCL has spent a hefty sum of Rs. 97.02 Crore (Petition Page 32) for meter
reading and other merchandizing services during FY 2021-22, in spite of which meter
readings are not done on regular basis. The Commission should disallow such huge
expenditure on out-sourcing of meter reading when 20-30% of meters are not being
read.
The Commission had directed CSPDCL to prepare an action plan and take corrective
measures to bring down percentage of defective meters and assessment-based billing
within prescribed ceiling under Tariff Order FY 2019-20 and again under Tariff Order
FY 2022-23. However, unfortunately nothing has been done, hence, disallowance
should be treated as punishment for non-compliance of directives.
The Objector submitted that the Commission in several Tariff Orders, has laid
emphasis on correct and timely preparation of R-15 report. However, there is no
uniformity in the submission of CSPDCL with respect to R-15 report, and it is very
difficult to have a „Bird‟s Eye-view‟ to have an overall picture of distribution system.
There are also several data-based and calculation errors due to which very purpose of
preparing R-15 report has been lost.
It is observed that R-15 format is being prepared by CSPDCL using SAP software and
the Commission is now authorized to look directly into the data fed into SAP system.
Therefore, it is desired that the Commission should inspect SAP data directly and
regularly for better feedback and control.
In absence of authenticated, reliable and reconciled data and information like R-15
format, True-up Petition, Additional Submission and Audited Balance Sheet and
Auditors‟ Report for FY 2021-22, the True-up exercise for FY 2021-22 should be
carried only after submission of uniform data and information by CSPDCL.

Petitioner’s Reply
CSPDCL submitted that the Commission has disposed Petition No. 53 of 2020
through its Order dated December 9, 2021 which was connected to compliance of
directives by CSPDCL in respect of Tariff Order for FY 2019-20. The Commission
after perusing the details of submissions made by respondent on each of the tariff
directive contained in the Tariff Order dated February 28, 2019, appreciated the
efforts taken by CSPDCL with specific observation to accelerate the efforts. The
directives include preparation of action plan and corrective measures to bring down
percentage of stop/defective meter and assessment based billings.
Further, the status of stopped and defective meters and cases of assessed billing are
demonstrated in revenue statement and the same are in pursuance to provisions of the
Supply Code. The difficulties in replacement of stopped and defective meters such as

24 CSERC Tariff Order FY 2023-24


diversity in locations of agriculture and BPL pumps, prolonged locked premises and
resistance of consumers towards meter replacement are prominent reasons for existing
status.
As regards to preparation of R-15, the contentions of Objector may be dismissed as
the Petitioner is following the directions of the Commission from time to time.
Commission’s View
The Commission has done prudence check on R-15 data submitted by CSPDCL and
accordingly approved the sales of CSPDCL. Further, the Commission observed that
the number of defective meters and billing based on assessment is still on the higher
side despite various directives given by the Commission in previous Tariff Orders.
The Commission has hence, given further directions to CSPDCL to submit a time
bound action plan to phase out defective meters and assessment billing, within three
months.

2.5.17 Submission of Compliance Report under Directives issued by the Commission in


previous Tariff Order FY 2022-23
The Objector submitted that CSPDCL has not submitted any “Compliance Report”
along with Tariff Petition for FY 2023-24. It is further observed that CSPDCL has not
complied with most of the directives issued by the Commission in order to facilitate
improvement in operational efficiency. In many cases, operation efficiency has further
deteriorated. Hence, the Objector requested the Commission to take strict action
against such lapses of non-compliance and non-submission of “Compliance Report”.

Petitioner’s Reply
CSPDCL submitted that they have complied with the Directives of the Commission
vide Letter no. 2772, dated 17.02.2023. It is further submitted that the compilation of
the directives took time and therefore the same is not been submitted with the Tariff
Petition. CSPDCL took all the measures to comply with the directives issued by the
Commission.

Commission’s View
CSPDCL submitted compliance report to the directives vide Letter no. 2772, dated
17.02.2023. The Commission has gone through the compliance report and
accordingly, issued subsequent directives in this order.

2.5.18 Discrepancy in CSPDCL’s Employee Cost , A&G, R&M Expenses


The Objector submitted that a discrepancy in the claim of employee cost has been
observed in the True-up Petition for FY 2021-22 when compared with Audited
Balance Sheet.
The Objector requested the Commission to:
a. Treat excess Employee Cost of Rs.1,017.36 Crore over approved Rs. 947.51
Crore in accordance to MYT Regulations‟ 2015;
b. Disallow claimed A&G and R&M expenses of Rs. 547.45 Crore in ARR and
treat excess expense of Rs.388.46 Crore over approved Rs. 280.26 Crore in
accordance to MYT Regulations‟ 2015;

CSERC Tariff Order FY 2023-24 25


Petitioner’s Reply
CSPDCL submitted that there is no deviation between the Petitioner‟s claim and
audited accounts as regards the employee expenses. The Objectors claim of adding the
outsourced manpower expenses in the employee expenses is contrary to the
Regulations. Hence, the objection is baseless and has been made contrary to the
Regulations. Also, CSPDCL has already submitted the reconciliation of the expenses
claimed by the Petitioner with the Audited Balance sheet.
Further CSPDCL submits that the R&M expenses as per the Accounts are Rs. 390.04
Crore, which has been claimed as R&M expenses. Further, the expenses of Rs. 64.26
Crore towards manpower expenses at 33/11 kV substations has been deducted while
claiming the sharing of gain and losses on account of O&M expenses. The R&M
expenses have been claimed strictly as per the audited accounts and there is no
multiplicity of the data as contended by the Objector.
Similarly, Rs.157.41 Crore has been claimed under the head A&G expenses after
adjustment of the capitalization of expenses, strictly as per the audited accounts and
there is no deviation. The Objector has wrongly adjusted the capitalization from R&M
expenses, which is resulting in confusion. The Commission is requested to consider
the submission of the Petitioner, which are as per the audited accounts.

Commission’s View
The Commission has approved the Employee Cost, R&M Expenses and A&G
Expenses in accordance with the applicable tariff regulations i.e. the MYT
Regulations, 2015 for true-up of FY 2021-22 and thus, not treated the expenses
towards contract services, viz., operations of 33/11 kV Substations, meter reading, bill
distribution and revenue collection, secretarial assistance in offices, housekeeping and
security guards under employee expenses and as uncontrollable. The same is detailed
at relevant chapter of the order.

2.5.19 Retail Tariff of Mini Steel Plants (HV4-Steel Industries)


Chhattisgarh Mini Steel Plant Association (CGMSPA) submitted that
Effect of Lock-down and COVID-19 Pandemic on Steel Industries:
The Objector submitted that due to first wave of COVID-19 Pandemic, the Central
and State Governments imposed Lock-down since March 23, 2020. Industries were
allowed to work in limited manner since 1st week of May 2020, by strictly observing
certain terms and conditions prescribed by the Government. The said Lock-down had
been effectively imposed till May 31, 2020 by issuing strict guidelines and
notifications. In second and third wave of Corona Pandemic, although the lock-down
was not strictly imposed, the procurement-production-marketing-monetary cycle of
Steel Industries of the State was very badly affected.
Under said circumstances, Steel Industries have been hit hard and are almost unable to
run normal production activities due to following reasons:
a. Complete Lock-down till 03.5.2020 and partially till 31.5.2020;
b. Labourers and Staff are not attending production activity due to threat to their
lives, migratory labourers have gone back to their respective States;
c. Raw-material is not available in required quantity;

26 CSERC Tariff Order FY 2023-24


d. Market and demand of goods has substantially diminished;
e. Financial cycle has been badly affected;
f. Huge liability of Minimum Electricity Bill during the period of closure.
The impact of above negative forces has resulted in actual sales to HV-4 category
being much lower than approved in FY 2022-23.
Hence, it is clear that Steel Industries, especially Mini Steel Plants, have suffered very
badly due to Corona Pandemic and have not recovered even to the level 2 years
before. This is a matter of great concern not only for industries but also for CSPDCL.
Looking at the seriousness of the situation, the State Government had announced
Tariff Subsidy up to Rs.1.22 per unit for Steel Industries having load of 2,500 kVA or
above till July 2021 and later Retail Tariff was also reduced by the Commission,
which is a highly welcome initiative taken by the Commission.
Lower Tariff in Neighbouring States:
The Objector submitted that some of the neighbouring States have announced
electricity tariff for Steel Industries quite lower/competitive to the existing tariff in
Chhattisgarh.
It is feared that trade and manufacturing activity may shift from the State to other
States, which may prove to be nightmare for the development of our State. Hence,
Retail Tariff of Steel Industries should be designed in such a manner that such
existing industries not only survive stiff competition from other States but are also
able to fetch fresh investment.
Post-COVID afresh Investment in the State:
The Objector submitted that in the post-Corona period, the State Government is trying
hard to attract fresh investment in the State by providing booster under State
Industrial Policy 2019-24. Hence, to achieve above objective, the growth of existing
industries is essentially required to be secured who are finding it difficult to survive in
the present scenario.
CSPDCL has reported a surplus of electricity by about 17.5% during FY 2023-24 and
such surplus power is proposed to be sold to other States at a price lower than
purchase price. In this manner, we are subsidizing other States, which is certainly not
our objective.
Therefore, the Objector prayed that the Retail Tariff and Incentives should be
designed in such a manner that they not only help in survival but also encourage the
consumption of electricity. To achieve above objective, following measures are
suggested:
a. Average Billing Realization from Bulk Consumers to CSPDCL should be near to
Voltage-wise Cost of Supply (FY 2022-23 - Rs.5.20 per unit for 33 kV supply
determined by the Commission excluding past revenue gap);
b. Suitable Bulk Consumption Incentive should be given over and above Load
Factor Incentive (Orissa Pattern);
c. Power-off hours should be increased to average 72 hours per month, considering
shutdowns and weekly-off days;

CSERC Tariff Order FY 2023-24 27


d. Additional Power Off Hours against Load Shedding should be provided based on
actual load shedding period, apart from existing normal power-off hours of 36
hours per month;
e. Only Night Tariff (optional) should be introduced to encourage consumption
during surplus period with allowing 12 hours working;
f. TOD Tariff Hours should be reset by reducing the peak period from 5 hours to 4
hours, reducing the normal period from 13 hours to 12 hours, and increasing the
off-peak hours from 6 hours to 8 hours.
g. Variable Cost Adjustment (VCA) to be reset to zero as it has gone up high as Rs.
1.10/kWh Mechanism for independent checking of computation of FCA and
VCA charges should added.
h. No additional charge be levied on exceeding contract demand up to a maximum
limit of 30% during off-peak hours. Correction in Clause 9(iii) of Terms &
Conditions of HV Supply be made to consider excess demand over 120% of
contract demand during off-peak hours as excess billing demand (example- CD
of 1000kVA is permitted to draw 1200kVA during off-peak hours and if suppose
during off-peak hours, recorded demand is 1210kVA then only on 10kVA,
provision of excess demand be applied.)
i. Advance Payment Rebate equivalent to DPS (presently 1.5% of the bill per
month or part) may be given to encourage advance payment of energy bills,
which will improve cash-flow of CSPDCL.
j. Mechanism for 15-day billing cycle be fairly devised in the benefit of Discom
and consumers.
The Objector made detailed submissions regarding the formulation of Only Night
Tariff, which provides an ABR of about Rs.5.25 per unit considering 60% load factor
(12 hrs) and 10% additional working during the period other than Normal (12 hrs) for
other essential operational activities like loading, unloading, cooling, production cycle
completion, office, etc.
Following issues are required to be fixed in consultation with CSPDCL:
a. Allowable Normal Working Hours for Only Night Tariff, which should be 12 hrs
minimum;
b. Metering and Billing issues;
c. Availability of Load in respective feeders during said period of 12 hrs, which can
be permitted on „first come- first get‟ basis, etc.
The Objector submitted that the Retail Tariff for Mini Steel Plants during FY 2023-24
should be designed considering Corona after-effects, package/ relief from the Central
Government, lower tariff in neighbouring States, sincere efforts of the State
Government to attract afresh investment and revenue contribution by Mini Steel
Plants over the years, etc.

Petitioner’s Reply
CSPDCL submitted point-wise reply to the measures suggested by the Objector as
under:
a. As regards Average Billing Realization from Bulk Consumers being near to
Voltage-wise Cost of Supply, it would be against the Tariff Policy Clause 8.3(2)

28 CSERC Tariff Order FY 2023-24


wherein consumer retail tariff is required to be determined within the limits of ±
20% of Average Cost of Supply.
b. Load factor incentive is a prerogative of the Commission under Section 62(3) of
Electricity Act, 2003. CSPDCL submitted that if this request is considered by the
Commission then approved ARR for FY 2023-24 should be protected.
c. The intention of power off hours is to compensate power intensive industries from
interruptions. The Commission has already revised duration of 30 hours to 36
hours recently in the Tariff Order dated August 2, 2021. The aforesaid revision is
based on average interruptions caused to industrial feeders across the area of
supply in the State. Applicant has not submitted any justifications for revision.
However, the availability of supply in EHV is 99.97%. Hence, the duration of
hour shall be minimized.
d. CSPDCL submitted that if the request of only night tariff is considered by the
Commission then approved ARR for FY 2023-24 should be protected.
e. The present TOD structure is appropriate as per availability of power.
f. The expenditure taken as difference of power purchase cost (CHPP) on bi-
monthly basis under the FCA and VCA mechanism observes separate annual
cycle specified at Regulation 67.8 of CSERC MYT Regulations, 2015 and
Regulation 93.10 of CSERC MYT Regulations, 2021.
g. The current billing provisions are governed by the supply code and regulations.
The Discoms are operating according to the provisions of the Regulations.
Therefore, CSPDCL humbly submits before the Commission that present TOD
tariff is appropriate.
h. The advance payment rebate already exists in the Tariff Design.
i. Billing frequency plays an important role in getting to know the status regarding
the timely regularization and realizations of revenue across distribution utilities in
different categories. It is in the common interest of both customers and
distribution utilities to regularize the billing schedule. CSPDCL humbly submits
before the Commission that present criteria for 15 days billing cycle is
appropriate.

Commission’s View
The Commission has addressed the issue of Load Factor Rebate for HV4-Steel
Industries Category along with the tariff philosophy and other terms and conditions of
tariff in the relevant Chapter of this Order. The category-wise tariffs have been
determined based on Average Cost of Supply and cross-subsidy level.

2.5.20 Sale/Consumption of Surplus Power within State


The Objector submitted that the Commission in Tariff Order for FY 2019-20, has
directed CSPDCL to examine the possibility of optimum utilisation of surplus power
within the State through appropriate incentive mechanism and to come up with a
proposal for same by November 30, 2019. However, CSPDCL has not submitted any
such proposal.

CSERC Tariff Order FY 2023-24 29


In the True-up Petition for FY 2021-22 and Tariff Petition for FY 2023-24, CSPDCL
has reported surplus availability of power of 3,612.34 MU and 7,075.87 MU
respectively (excluding sale to Telangana in spite of much lower drawal against
Central Allocation of power from Central Generating Stations), which is sold at Rs.
3.20/kWh and 4.94/kWh as against average power purchase cost of Rs. 4.27/kWh.
and Rs. 3.71/kWh for FY 2021-22 and FY 2022-23 respectively.
The above quantum of surplus power amounts to more than 24.5% of retail sale of
power of 25,885 MU during FY 2023-24. It is observed that CSPDCL is paying
capacity charges to about 4 to 5 CGS stations (NTPC) without drawing any power
from them due to surplus availability. Also, about 25% of the Retail Sale & 17.5% of
net Power Purchase is disposed-off by CSPDCL to other States at very low realization
(below average procurement cost) and the burden of such disposal of power to other
States is borne by the consumers of Chhattisgarh by way of higher tariff. Hence, if
such power can be utilised within the State at relatively higher realization, it shall
prove to be beneficial to CSPDCL and consumers as well.
Further, the Commission had registered a suo-motu Petition (P.No.59/2020) on
representation of industries to find ways to utilize surplus power within the State. In
the Order dated December 10, 2020, the Commission had directed industries to take
up the matter during discharge of Tariff Petition for FY 2021-22 and also directed
CSPDCL to submit detailed data and proposal to achieve above objective.
Due to favourable policies, market conditions and State Subsidy, Steel Industries have
grown beyond estimations during FY 2020-21 and FY 2021-22 and have delivered
major revenue to CSPDCL.
The tariff of Steel Industries is considerably reduced and anomalies are removed,
considering negative impact of economic slowdown and effect of Covid-19. Hence,
CSPDCL should be directed to make efforts to sell this surplus quantum of power to
the consumers of the State as directed by the Commission. Therefore, a mechanism
has to be devised so that:
a. Consumers may get benefit of surplus power, at cheaper rates, (which is otherwise
sold/ surrendered to other States at loss-making rate) over and above their existing
consumption;
b. Having slight better realization from retail consumers compared to Rs.3.71 (gross
average power purchase cost estimated for FY 2023-24 by CSPDCL), revenue of
CSPDCL will be improved;
c. State Government will be benefited by way of additional taxes and revenue on any
possible increase in production of industries;
d. Public may be benefited by way of more employment due to increased production.
The Objector submitted that the above measures may be designed in such a manner
that it may prove beneficial to CSPDCL by way of sale of surplus power at profit-
making rate when there is no demand of such power in inter-State market and also to
Steel Industries of the State by way of lower tariff when they are badly suffering from
economic slowdown and after-effect of Corona Pandemic. Any operational
constraints may be resolved under consultation with CSPDCL and consumers.

30 CSERC Tariff Order FY 2023-24


Petitioner’s Reply
CSPDCL submitted that it anticipates a TOD surplus ranging between 100 MW to
1500 MW in the system during off-peak hours of winter and day time subject to
commissioning of solar plants during the next Control Period. As consumer sale
requires RTC surplus; hence, the present suggestion is senseless.

Commission’s View
In the present Order, the Commission has made a reasonable assessment of the
surplus quantum to be sold in the Power Exchanges for the Control Period, and has
considered some short-term purchase from Power Exchanges to meet the energy
requirement. However, during the Control Period, there are bound to be mismatches
between demand and supply, and CSPDCL should strive to maximise the revenue
from such sale of surplus power.

2.5.21 Distribution loss including EHV Sales


The Objector submitted that CSPDCL is unable to match with its commitment in
“UDAY Scheme” and “Revamped Distribution Sector Scheme” in the matter of
Distribution Losses in spite of huge capital expenditure, resulting in burden on Retail
Tariff of consumers. Proposal of Distribution Loss at 11.54% for FY23-24 is
unrealistic.

Petitioner’s Reply
CSPDCL submitted that CSPDCL would like to consider the losses of 15.33% as
approved by CSERC, the cumulative losses for FY 2023-24 after considering EHV
consumers comes out 11.54%. Also, CSPDCL would like to submit that it has
followed the distribution loss trajectory as approved by the Commission and putting
its best efforts to increase the revenue realization and to manage the cost side more
efficiently.

Commission’s View
The Commission has projected sales based on cumulative average growth rate
considering R-15 submitted by CSPDCL. As per the computation of the Commission,
the distribution loss including EHV sales works out to be 13.67% as against 11.54%
submitted by CSPDCL which appears to be a realistic assessment.

2.5.22 Change of Tariff Category


The Objector submitted that the process in Printing Industries involves several steps
to manufacture variety of finished products. During the discharge of tariff petition of
FY 2022-23 the objector has requested the Commission to classify the Printing
Industries under LV5 - LT Industries instead of existing LV2 - Non-Domestic
category. In its response, the Commission has expressed its views in a subjective
manner that “Printing Industries, though an industry, cannot be categorized under
industrial tariff category”, without citing any reason.
The Objector submitted that the Commission is required to adopt an objective,
analytical and reasoned approach while deciding tariff category of Printing Industries.

CSERC Tariff Order FY 2023-24 31


Petitioner’s Reply
CSPDCL submitted that determination of retail supply tariff and differentiating
among consumers while tariff determination, is a prerogative of State Commission
under section 62(3). The retail supply tariff of a consumer category has to be within
the limits of +20% of Average cost of supply. Further, if the applicant request
considered by the Commission the petitioner proposal ARR for the FY 2023-24 shall
be protected. In addition to the above contentions raised by objector that are not
specifically admitted are denied.

Commission’s View
Hon‟ble APTEL in order dated 07.08.2014 passed in appeal no. 131 of 2013 in the
matter of Vianney Enterprises V. Kerala State Electricity Regulatory Commission,
held that the categorization of consumer for the purpose of electricity tariff is under
the domain of the State Commission under the Electricity Act, 2003. Under Section
62(3) of the Electricity Act, the State Commission can differentiate between the tariffs
based on purpose for which the supply is required. The State Commission is
empowered to differentiate in tariff based on a purpose for which the supply is
required. Considering the above, the Commission has not found any merit, therefore,
tariff category of printing industries is kept unchanged.

2.5.23 Promotional Electricity Tariff for ‘Export Oriented Units’


The Objector requested the Commission to extend the scope of promotional electricity
Tariff granted to export oriented Textile industries to other Textile industries also.

Petitioner’s Reply
CSPDCL submitted that determination of retail supply tariff and differentiating
among consumers while tariff determination, is a prerogative of the Commission
under Section 62(3) of the Act. In the capacity of Distribution Licensee, CSPDCL
submitted that the aforesaid request of the Objector may be considered subject to
protection of Petitioner‟s approved ARR for FY 2023-24.

Commission’s View
The detailed rationale and tariff philosophy adopted by the Commission, while
determining the category-wise tariff for FY 2023-24 is given in the relevant Chapter
of this Order.

2.5.24 Voltage-wise Cost of Supply


The Objector submitted that Hon‟ble APTEL in its Judgment in Appeal No. 102 of
2010 dated May 30, 2011, provided the guidelines for calculation of cost of supply
calculation. CSPDCL is continuously following the same method for calculating the
cost of supply and has proposed tariffs accordingly, without considering the
development in metering network and availability of actual voltage-wise losses. Due
to this, the consumers who are having connectivity at 220 kV voltage are compelled
to bear both the transmission losses as well as distribution loss.
The objector also requested the Commission to direct CSPDCL to take steps to reduce
losses, not to entertain the CSPDCL‟s proposal to abolish the existing provision of
power off hours under HV 4 – Steel Industries category.
32 CSERC Tariff Order FY 2023-24
Petitioner’s Reply
CSPDCL submitted that the applicant‟s request to consider Voltage-wise Cost of
Supply in tariff determination is misplaced in light of the fact that the Commission
has already differentiated the energy charges for HV-4 tariff category on the basis of
voltage of supply. It is pertinent that energy charges for 220 kV and 132 kV are
substantially less than energy charges for 33 kV and 11 kV voltage.
The Hon‟ble Supreme Court in the matter of Punjab State Power Corporation Limited
V/s Punjab State Electricity Regulatory Commission & Ors. in Civil Appeal No. 4510
of 2006 decided on 10.02.2015 [(2015) 7 Supreme Court cases 387] has already
upheld principles of cost of supply and cross subsidy. Accordingly, the present tariff
structure in respect of HV-4 tariff category wherein different energy charges are
determined for different supply voltages, is consistent with the aforesaid legal
principle settled by the Hon‟ble Supreme Court.
Further, retail supply tariff is statutory function of the Commission and while
discharging this function it is guided by the Tariff Policy. According to Clause 8.3(2)
under „tariff design‟ of Tariff Policy notified on 28.01.2016, the retail supply tariff of
a consumer category has to be within the limits of + 20% of Average Cost of Supply.
In view of the above, the request of the applicant to consider Voltage-wise Cost of
Supply for retail tariff determination is baseless and need not be taken into
consideration.

Commission’s View
The approach of the Commission regarding determination of Voltage-wise Cost of
Supply is given in the relevant Chapter of this Order. The Commission has already
implemented differential tariffs within a consumer category based on the supply
voltage, and consumers taking supply at higher voltages are required to pay lower
tariff, as compared to consumers taking supply at lower voltages. These changes have
been retained in this Tariff Order also.

2.5.25 Projected revenue, Energy balance, Parallel Operation Charges and Power
purchase Cost
The Objector submitted that ARR of CSPDCL for 2023-24 is Rs.15581.14 Crore,
whereas projected revenue at existing tariff and charges is Rs. 19,344.17 Crore which
is surplus of 3763.03 Crore and petitioner wants to recover entire previous gap
through the existing tariff which is already over estimated.
In view of this, objector requested the Commission to provide tariff relief to the
consumers and reduction in parallel operation charges considering a huge revenue
surplus.
Objector submitted that the projected energy balance for financial years 2022-23,
2023-24, in the CSPDCL petition, where sales projection for all categories are
increasing every year, but unfortunately on the point of energy losses for below 33
KV (in%) is projected almost same without any positive corrections. Hence requested
the Commission to reduce the losses as it impacts on the tariff specially for EHV
consumers

CSERC Tariff Order FY 2023-24 33


Power Purchase cost is also a major component of tariff. It needs to consider the
voltage wise power purchase rate by CSPDCL and taking into account of this needs to
access the actual cost of purchase for different category of consumers instead of
uniform rate of purchase.

Petitioner’s Reply
CSPDCL submitted that the revenue earned through Parallel operation charges is
among the constituents of non-tariff income. Any rationalization among such
constituents would have a bearing on tariff of normal electricity consumers. As
CSPDCL has requested to continue the existing tariff design in present tariff proposal,
hence any consideration to applicant‟s present request may cause additional burden on
other consumers.
CSPDCL submitted that the applicant‟s contention on projected revenue at existing
tariff charges FY 2023-24, Energy balance for FY 2022-23 and FY 2023-24 & Power
purchase cost need not require any comments as the same have been dealt in the tariff
petition in details. Furthermore applicant has also not objected any specific point
about tariff petition.

Commission’s View
As regard the revenue surplus projected by CSPDCL, it is pertinent to mention that
this revenue surplus is stand-alone revenue surplus for FY 2023-24 whereas when the
revenue gap of FY 2021-22 is taken into account, no surplus remains. Hence, request
of the objector to reduce the parallel operation charges cannot be accepted.

2.5.26 Provision of Power Off hours


The Objector submitted that the Commission should not entertain the CSPDCL's
proposal to abolish the existing provision of power off hours under HV-4 steel
industry category for the HT consumer of above 33 KV voltage.

Petitioner’s Reply
CSPTCL has submitted on their tariff petition no. 94/2022 that the Transmission
System Availability Factor (TSAF) for above 33 KV line (i.e. 400 kV, 220 kV & 132
kV) is 99.77% for FY 2021-22. Hence, CSPDCL has requested in petition to abolish
the existing provision of Power off hours under HV-4 Steel Industries category for the
HT consumer at EHV connectivity.

Commission’s View
The Commission has observed that the TSAF for networks 132kV and above is
99.77%, therefore, outage in 132kV and above system is almost negligible. Hence, the
Commission has accepted the request of CSPDCL for abolishing power off hours for
132kV and above system.

2.5.27 Revenue from Existing Tariff


The Objector submitted that there is lack of transparency in estimating revenue from
the existing tariff particularly from Railway and Steel Industry. ABR of Railway and
Steel Industry comes out to be Rs. 7.41 per unit. Such huge ABR indicates that the

34 CSERC Tariff Order FY 2023-24


Petitioner has deliberately not considered huge load factor rebate allowed to both
categories.

Petitioner’s Reply
CSPDCL submitted that in response to specific query of the Commission, CSPDCL
has submitted detailed reply showing revenue from sale of power at existing tariff for
FY 2023-24 incorporating the implications of load factor rebate allowed by the
Commission in the Tariff Order for FY 2022-23, impact of TOD tariff with details of
TOD time slot, vide submission through Letter No. 2626 dated February 03, 2023.

Commission’s View
The Commission‟s analysis on the revenue from existing tariff has been detailed in a
relevant Chapter of this Order. The Commission has considered the impact of load
factor rebate for HV-1 and HV-4 category, while computing the revenue from
existing tariff for FY 2022-23.

2.5.28 Revenue Gap/Surplus for FY 2021-22


The Objector submitted that CSPDCL has not revealed under-recovery/over-recovery
of revenue from consumers with reference to the estimation/approval in the Tariff
Order. The Objector objected to the ARR submitted by CSPDCL and sought relief on
following:
a. Under-recovery (i.e., difference between actual ABR and ABR approved in Tariff
Order multiplied by units sold to such category of consumers) from Steel Industry
(HV-4) and Railway (HV-1) should be worked out for FY 2019-20 and previous
years and financial impact should be loaded to the same category of consumers.
b. To maintain transparency, CSPDCL should be instructed to share the details of
above calculations considering load factor rebate and share with public.
c. To keep steel industry as subsidizing category, the load factor rebate needs to be
withdrawn/ abolished.

Petitioner’s Reply
CSPDCL submitted that the contentions raised by the Objector regarding retail tariff
determination are connected to previous Tariff Orders and proposal for ensuing year.
With regard to contentions on retail tariff determination for the previous years,
CSPDCL submitted that the Tariff Orders of all previous except FY 2022-23 (Tariff
Order dated April 13, 2022) have attained finality as each of these have completed the
term after issuance of subsequent Tariff Orders. Under the adopted practice, every
change in existing tariff design is supported by justification and reasons in respective
Tariff Order by the Commission. Facts demonstrate that the Objector have not
exercised remedies available under the Act, in terms of examining the legality,
propriety and correctness of these Orders.
Under such circumstances, raising issues with regard to previous Tariff Orders before
the Commission again would be inappropriate and abuse of regulatory process. In
light of the above, the Petitioner submitted that it would not like to comment on
contentions raised by the Objector on tariff determination of previous Tariff Orders.
CSPDCL submitted that the Revenue Gap at Table No. 26 is computed according to

CSERC Tariff Order FY 2023-24 35


the regulatory practice adopted by the Commission. Pursuant to such practice, the
estimation of expenses and revenue is compared with actual expenses and revenue in
terms of audited accounts at the time of truing up to get stand-alone gap position of
CSPDCL for FY 2021-22. The Table also includes additional gap arising out of
Review Petition included at Chapter 5 of present Tariff Petition.
Further, the projections of revenue for ensuing year, i.e., FY 2023-24 are also done by
applying existing tariff on estimated sales discovered on the basis of scientific
methodology described at Para 8.6 to 8.8 of the Tariff Petition. Additionally,
CSPDCL has also provided the revenue implications arising out of implementation of
load factor rebate and TOD in response to data gaps raised by the Commission
pursuant to prudence check.
CSPDCL submitted that the Objector‟s contention on closing deficit for FY 2021-22
do not require any comments as the same have been dealt in the Tariff Petition in
detail. Further, CSPDCL has also submitted reply to data gaps/additional points on
Tariff Petition to the Commission under prudence check.

Commission’s View
The Commission has adjusted the Revenue Gap/(Surplus) arrived at based on final
true-up of FY 2021-22, with the stand-alone Revenue Gap/(Surplus) of FY 2023-24,
and the tariffs have been designed based on the cumulative Revenue Gap/(Surplus) as
per the methodology adopted in previous Tariff Orders.

2.5.29 Retail Tariff Proposal


The Objector submitted that CSPDCL has not submitted any proposal related to
change in terms of current tariff applicable in year 2023-24 that means the petitioner
wants to continue with same terms and condition of current tariff applicable in year
2022-23. Therefore, the objections in reference to the terms and conditions of current
tariff applicable in FY 2022-23, are that, since, the objective of the rebate is to
increase the utilization of power supply from CSPDCL, this facility of Load Factor
rebate should not be applicable to those consumers in HV-4 category having captive
generating facility with installed capacity above 1 MW. This will encourage higher
consumption by this subsidizing category, which would Improve the revenue of
CSPDCL.
Whereas after allowing huge Load Factor rebate (LF rebate in short) the actual
average billing rate to such steel industries consumer is less than Rs. 5.41 per unit i.e.,
almost 1 Rs lower than ACoS of Rs.6.41 and thus it will become de facto a subsidized
category.
In tariff order FY 22, nowhere any justification / financial calculation was given why,
the cut-off of load factor for rebate shifted upward from 63% to 50%, it is totally
baseless and giving undue benefit to particular class/ section of Steel industry
consumers. Similarly, there is no technical/financial justification of giving higher load
factor rebate on energy charges of entire consumption.
The criteria and quantum of load factor rebate allowed to railway and steel industries
are different, whereas as per economic considerations it is not appropriate therefore,
we request with the Commission that if load factor rebate has to be allowed then the
criteria and quantum of load after rebate must be same for all class of consumers but

36 CSERC Tariff Order FY 2023-24


should be limited to Steel industry and Railway like power factor improvement
penalty/incentives are being allowed.
The quantum of load factor (30%) rebate being allowed to railway is huge and
resulting very 1ow realization as ABR, therefore we request with the Commission to
reconsider the basis of such huge load factor rebate and tariff for railway as
comparison to the same of all neighbouring states.

Petitioner’s Reply
CSPDCL submitted that under Section 62(3) of the Act, the Commission has powers
to determine retail tariff of different consumer categories and differentiate among the
consumers on grounds of consumer 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. CSPDCL has not proposed any change in
tariff design in respect of steel industries and requested the Commission to kindly
continue the existing tariff design.
CSPDCL requested the Commission to consider the Objector‟s prayer subject to
protection of approved ARR of CSPDCL for FY 2022-23.

Commission’s View
The Commission has adjusted the Revenue Gap/(Surplus) arrived at based on final
true-up of FY 2021-22, with the stand-alone Revenue Gap/(Surplus) of FY 2023-24,
and the tariffs have been designed based on the cumulative Revenue Gap/(Surplus) as
per the methodology adopted in previous Tariff Orders.

2.5.30 Excess Rebate in Time of the day Tariff (TOD)


The Objector submitted that as per Tariff order FY 2022-23 clause 30. p), reproduced
below as: -
30 p) In order of better utilize the surplus power available with CSPDCL especially
during night off-peak hours, the tariff for night-time consumption has been reduced
from 75% to 65% of normal rate of energy charge.
Whereas the factor of TOD is less than 1 i.e., 95.4%, when hourly consumption
pattern remains unchanged for 24 hours; thus, if any continuous industry opts TOD
tariff without changing its consumption pattern, he will get benefit of reduction in
tariff by 4.6% without contributing anything to distribution company‟s demand curve,
which setbacks the purpose of TOD tariff. And this may affect expected revenue
calculation by more than 400 Crore.

Petitioner’s Reply
CSPDCL submitted that the present TOD method is appropriate as per commercial
matrix in respect of availability of power.

Commission’s View
For deciding the TOD tariff, the Commission sought the relevant data from SLDC.
Considering the data provided by SLDC, the Commission has revised the TOD tariff
and the same is given in tariff schedule chapter.

CSERC Tariff Order FY 2023-24 37


2.5.31 Prepaid Smart Meter
The Objector submitted that CSPDCL daily publishing news related to pre-paid smart
meters in local newspaper and spreading panic among consumers but not said
anything specific in this petition. They should be asked to clarify following issue
related to the scheme: -
i. In RDSS scheme when there is only one compulsion of installing pre-paid smart
meters in Govt connection then what is the necessity that CSPDCL is bent upon to
install pre-paid smart meters in more than 50 Lakh consumers.
ii. Is there any success story for similar case, in any part of India?
iii. Who is going to bear the residual cost of more than 50 lakh electronic old meters
and infrastructure of reading, billing, collection?
iv. Have CSPDCL done activity-based costing for reading, billing, and collection,
activities if yes then the same may be published in public domains
v. What may be the charges be paid to the contractor for his services of per-paid
meters?
vi. In case of BPL consumers, the energy charges are being subsidized by Govt of CG
and if smart meter are placed in their premises, then who will bear the O&M
changes including depreciation charges etc. of per-paid smart meters.

Petitioner’s Reply
CSPDCL submitted that the Pre-paid smart meters are not connected to CSPDCL‟s
Tariff Petition, hence, no comments are offered. But, CSPDCL already submitted the
details of the RDSS scheme under petition no. 04/2022 in the matter of the Capital
Investment Plan for FY 2022-23 to 2024-25. Accordingly, Capital Investment Plan
for FY 2022-23 to 2024-25 has approved by Commission.

Commission’s View
The Commission has found that concerns raised by the objector are not related to the
present petition and hence, are not considered.

2.5.32 Sale of Surplus power and Tariff hike


As regards sale of surplus power, the objector submitted that at page 60, CSPDCL
stated that it will sale 7075.87 MU surplus power and collect Rs. 3495.48 Crore
which seems unrealistic.
As regards tariff hike, the objector submitted that CSPDCL has not proposed any hike
in tariff whereas it has projected a revenue deficit of Rs. 2371 Crore and this may be
due to political compulsion of coming state assembly election. As per APTEL‟s
decision normally no regulatory asset can be created thus there is no alternate remains
other than hike in tariff specially of Steel Industry category.

Petitioner’s Reply
CSPDCL submitted that surplus power, if any, shall be sold to retail consumer of the
State as well as on exchange/utilized for banking purpose.
CSPDCL submitted that determination of tariff for retail sale is prerogative of the
Commission U/s 62(3) of the Electricity Act 2003, hence CSPDCL has submitted its

38 CSERC Tariff Order FY 2023-24


request for rationalized tariff for all consumer categories required to meet the
approved gap. CSPDCL requested the Commission to approve the same.

Commission’s View
In the present Order, the Commission has made a reasonable assessment of the
surplus quantum to be sold in the Power Exchanges for the Control Period, and has
considered some short-term purchase from Power Exchanges to meet the energy
requirement.
The Commission has adopted various tariff rationalisation measures to recover the
approved annual revenue requirement of CSPDCL.

2.5.33 Railway Tariff


The Objector submitted the Railways is a public utility and a bulk customer.
Therefore, Railways should be provided with favourable tariff formulation so that
CSPDCL and Railways can serve the Nation as well as the State together. The
Objector hence, requested the Commission to reduce tariff for HV-1 (Railway
Traction). Railway should be provided electricity @ economical single part tariff for
their traction connection. Further, the tariff for non-traction load of Railways in HV-3
category should be reduced. All non-traction load should be considered under LV-6
(Public utilities) tariff category.
The reasons provided by the Objector are as follows:
a. It is a base load consumer with average load factor of 30 to 40%;
b. Railways being a Deemed Licensee should be provided power at Average Power
Purchase Cost;
c. Article 287 of the Constitution of India forbids States from imposing any kind of
tax on the consumption or sale of electricity, which is consumed by Railways;
d. Railway is playing a very important role in sustainable development of the State
utilising energy efficient measures. By further rationalising tariff, it would help
Railways justify the expenditure.

Petitioner’s Reply
CSPDCL submitted that the Objector has not made any comments on the Tariff
Petition. The contention that the Objector may be treated as deemed licensee, does not
require any consideration in light of the fact that such issue is not connected to the
subject matter of present Tariff Petition. Further, the benefit of load factor rebate is
already extended to Railway traction tariff under HV-1 category where traction sub-
stations attaining load factor above 20% are availing rebate of 20% in billing of
energy charges, under existing tariff design. Hence, consideration of single part tariff
being HT consumer will encourage other HT consumer for the same.
The request for treatment of non-traction load under LV-6 tariff category is an issue
related to tariff design, which falls under the realm of the Commission. Under a
conscious decision, bulk supply at one point to establishments applicable to consumer
like Railway is categorised as HV-3 (other industrial and general purpose non-
industrial), which is to meet commercial implications of mixed load in same premises
availing non-traction connection. Further, request to include non-traction load under
LV-6 tariff category may also observe the limitations of electrical safety involved in

CSERC Tariff Order FY 2023-24 39


issuing electricity connections simultaneously of HV/LV in same premises and more
so, this issue is controlled by the Supply Code and not by Tariff Order.

Further, the request of the Objector to reduce tariff of HV-1 and HV-3 tariff
categories requires examination of Tariff Policy Clause 8.3(3) wherein it is stipulated
that consumer tariff has to remain within the limits of + 20% of average cost of
supply. Pursuant to load factor rebate in HV-1 tariff category, applicant is already
availing the benefit of subsidized tariff category. Hence, request for further tariff
reduction would be unfair.

Commission’s View
The detailed rationale and tariff philosophy adopted by the Commission, while
determining the category-wise tariff for FY 2023-24 is given in the relevant Chapter
of this Order. The detailed Tariff Schedule applicable for FY 2023-24 is given in the
Tariff Schedule Chapter of this Order.

2.5.34 Educational institution in LV1 category


The Objector has requested the Commission to delete "Educational institutions
controlled by firms and society regd. as non-profit organisation" from LV-1 category
so that electricity can be supplied to poor people at justified rate and retain
"educational institution controlled by Govt. and Registered religious organisation" in
LV-1 category.

Petitioner’s Reply
CSPDCL submitted that it is prerogative of the CSERC to decide the applicability of
any tariff category therefore it is upto the Commission to take any view on the
suggestion of the objector.

Commission’s View
The detailed rationale and tariff philosophy adopted by the Commission, while
determining the category-wise tariff for FY 2023-24 is given in the relevant Chapter
of this Order. The detailed Tariff Schedule applicable for FY 2023-24 is given in the
Tariff Schedule Chapter of this Order.

2.5.35 Provision of LT connection


The Objector has requested the Commission to make a provision to issue LT
connection upto 265 HP (200 kW) and to introduce TOD tariff in LT tariff category
also.

Petitioner’s Reply
CSPDCL submitted that the issue of LT connection upto 265 HP (200 kW) is not
related to present tariff petition therefore there is no need to comment anything on this
issue. As regards to introduction of TOD tariff, CSPDCL submitted that the issue is
prerogative of the Commission therefore it is upto the Commission to take any view
on the suggestion of the objector.

40 CSERC Tariff Order FY 2023-24


Commission’s View
The Commission has already enhanced load limit from 100 HP to 150 HP at low
voltage level. It is not technically feasible to enhance the limit further to or 265HP.
The proposal of the objector for introducing TOD tariff in LT connections may be
considered once the smart meters are installed.

2.5.36 Issues raised by the small shopkeepers


The Objector has requested the Commission;
i. To extend the facility of electricity bill half scheme to small shopkeepers in
line with electricity bill half scheme provided to domestic consumers.
ii. To revise the prevailing VCA charges to rationalize it.
iii. To make tariff of consumers who are getting electricity from single point
consumer of CSPDCL, equal to the tariff applicable to consumers of
CSPDCL.
iv. To retain the industrial category tariff of consumers who were initially issued
industrial connection but CSPDCL has converted the same to non-domestic
tariff category.
v. To make provision for providing multiple connections in single premises
because different types of activity is being performed in same premises.
vi. To shift some frozen food plant to agriculture allied tariff category who are
being presently billed as per non-domestic tariff category.

Petitioner’s Reply
CSPDCL submitted the following observations as:
i. It is a jurisdiction of the State Govt. to introduce electricity bill half scheme to
small shopkeepers therefore CSPDCL has no comments on this issue.
ii. VCA charges is being levied in accordance with the CSERC MYT Regulation,
2021, therefore, this issue is not related to the present petition.
iii. & iv. Subject matter does not pertain to this petition.
v. Matter pertains to the provisions of the supply code not to this petition.
vi. It is the jurisdiction of the CSERC to decide applicability of the tariff category
to a specific class of consumers therefore CSPDCL need not to comment
anything on this issue.

Commission’s View
The Commission has no jurisdiction to introduce electricity bill half scheme to small
shopkeepers. VCA charges is being levied in accordance with the CSERC MYT
Regulation, 2021, therefore, this issue is not related to the present petition. Issue of
providing multiple connections in same premises is also not related to this petition.
The detailed rationale and tariff philosophy adopted by the Commission, while
determining the category-wise tariff for FY 2023-24 is given in the relevant Chapter
of this Order.

CSERC Tariff Order FY 2023-24 41


2.5.37 Issues of extending electricity half bill to temporary domestic connection
The objector has requested to extend the facility of electricity half bill scheme to
temporary domestic connections also.

Petitioner’s Reply
CSPDCL submitted that it is the jurisdiction of the State Govt. to introduce electricity
bill half scheme therefore CSPDCL has no comments on this issue.

Commission’s View
It is the jurisdiction of State Govt. to extend electricity bill half scheme to any class of
consumer, therefore, this matter should be raised before appropriate forum.

2.5.38 Issue of extending domestic tariff to private hostels


The objector submitted that as per prevailing tariff order, domestic tariff is applicable
to government hostels whereas private hostels are being charged as per non-domestic
tariff category. Therefore, objector has requested to the Commission to remove the
anomaly and extend domestic tariff to private hostels.

Petitioner’s Reply
CSPDCL submitted that determination of retail supply tariff and differentiating
among consumers while tariff determination, is a prerogative of State Commission
under section 62(3). Further, if the applicant request considered by the Commission
the petitioner proposal ARR for the FY 2023-24 shall be protected.

Commission’s View
The detailed rationale and tariff philosophy adopted by the Commission, while
determining the category-wise tariff for FY 2023-24 is given in the relevant Chapter
of this Order. The detailed Tariff Schedule applicable for FY 2023-24 is given in the
Tariff Schedule Chapter of this Order.

2.5.39 Issue of Tariff Classification of Wooden Door Manufacturing Industries under


LV Supply
The Objector submitted that there are about 75 Wooden Door Manufacturing
Industries in Chhattisgarh, registered with Department of Industries. These are very
small industries having connected load of 25-50HP only and are members of CECC.
After inspection, CSPDCL has billed them under LV2- Non-Domestic Category
instead of LV5- LV Industries stating that „Wooden Door Manufacturers‟ are covered
under „Furniture Maker‟.
Objector further submitted that the Hon‟ble Supreme Court of India has defined
„Furniture‟ as movable item and subject of convenience whereas Doors are not
movable item and are basic requirement of a premise for security and privacy
purpose. Hence Doors cannot be termed as Furniture.
In view of the above, the objector submitted that Tariff Category LV5- LV Industries
will be applicable to Wooden Door Manufacturing Industries, who are certainly not
“Furniture Makers”.

42 CSERC Tariff Order FY 2023-24


Petitioner’s Reply
CSPDCL submitted that determination of retail supply tariff and differentiating
among consumers while tariff determination, is a prerogative of State Commission
under section 62(3). Further, if the applicant request considered by the Commission
the petitioner proposal ARR for the FY 2023-24 shall be protected. In addition to the
above contentions raised by objector that are not specifically admitted are denied.

Commission’s View
The Commission has considered the objection and found the present categorisation
appropriate and self-explanatory, hence, no changes have been made in the tariff
category.

2.5.40 Tariff for LT Industries


The Objector submitted that the rural incentive of 5% on Energy Charges, existing
Adivasi Area Incentive for Bastar and Saguja and 10% rebate on Energy Charges to
Women Self-help Groups should be continued. Food Processing Units should be
given 5% rebate on Energy Charges in line with 5% rebate to HT Rice Mills.
Only Night Tariff may be introduced to encourage consumption during the night
hours. Load factor incentive may be introduced in similar way as given to HT
industries and as made available to LT Industries in MP so that more electricity
consumption will be encouraged using the same infrastructure. Further, power factor
penalty below 0.90 made applicable since 01.08.2021, should be rolled back to earlier
level of 0.85. Power factor incentive may be given step-wise on each point
improvement above 0.85.
The objector also submitted that tariff for LT Industries should be reduced and
existing supply affording charges should be reviewed.

Petitioner’s Reply
CSPDCL submitted that it has not given any specific proposal for retail tariff
determination. It is submitted that the retail tariff determination is the prerogative of
the Commission under Section 62 of the Electricity Act, 2003.
Further the suggestions related to Supply affording charges is related to the Supply
Code and may not be dealt in the matter of Tariff. In addition to the above contentions
raised by objector that are not specifically admitted are denied.

Commission’s View
The Commission has continued the rebate as requested by the objector. The detailed
rationale and tariff philosophy adopted by the Commission, while determining the
category-wise tariff for FY 2023-24 is given in the relevant Chapter of this Order. The
detailed Tariff Schedule applicable for FY 2023-24 is given in the Tariff Schedule
Chapter of this Order.

2.5.41 Tariff for Agriculture Consumers


The Objector submitted that the existing tariff for Agriculture Consumers is quite high
and near to the level of agriculturally rich States. Farmers of Chhattisgarh are poor

CSERC Tariff Order FY 2023-24 43


and any tariff increase from the existing level shall prove to be detrimental to the
farmers. Therefore, there should be no increase in tariff for Agriculture Consumers.

Petitioner’s Reply
CSPDCL submitted that determination of retail supply tariff and differentiating
among consumers while tariff determination, is a prerogative of State Commission
under section 62(3). The retail supply tariff of a consumer category has to be within
the limits of +20% of Average cost of supply. Further, if the applicant request
considered by the Commission the petitioner proposal ARR for the FY 2023-24 shall
be protected. In addition to the above contentions raised by objector that are not
specifically admitted are denied.

Commission’s View
The Commission, in this tariff order, has not increased tariff applicable to agriculture
category. The philosophy and rationale adopted by the Commission is detailed in the
relevant Chapter of this Order.

2.5.42 Tariff for Oxygen Plant


The Objector submitted that in the previous Tariff Orders, oxygen plant got
concession of 10% on energy charge but at the same time tariff and VCA was
increased. Therefore, effectively oxygen plants have got negligible benefit of
concession.
The Objector‟s request is to move standalone oxygen plants into HV-8 (Industries
related to manufacturing of equipment for power generation from renewable energy
sources) or HV 4 (Steel industries).

Petitioner’s Reply
CSPDCL submitted that determination of retail supply tariff and differentiating
among consumers while tariff determination, is a prerogative of State Commission
under section 62(3). Further, if the applicant request considered by the Commission
the petitioner proposal ARR for the FY 2023-24 shall be protected. In addition to the
above contentions raised by objector that are not specifically admitted are denied.

Commission’s View
The Commission after considering the views and suggestions of all objectors has
approved the Tariff for FY 2023-24. The philosophy and rationale adopted by the
Commission is detailed in relevant chapter of this Order.

2.5.43 Delayed Replacement of Burnt/Damaged Transformers


The Objector submitted that CSERC has expressed in Tariff Order FY 2022-23 that if
distribution transformer gets damaged, consumers are pressurised to clear dues as a
precondition of replacement of such transformer. Therefore, CSPDCL should be
directed for replacement of all burnt/ damaged transformers to supply power to
Agriculture consumers. The Commission has noted the objection on delayed
replacement of burnt/ damaged transformers by CSPDCL. CSPDCL is directed to
replace such transformers as per the timelines specified in the Standard of

44 CSERC Tariff Order FY 2023-24


Performance Regulations. However, the consumers also have the obligation to clear
their dues as per the bills raised by CSPDCL.
But the situation in the field remains the same in spite of above direction. Hence the
Objector is requested to the Commission to instruct for immediate replacement of all
burnt/ damaged transformers relating to supply to Agriculture Consumers.

Petitioner’s Reply
CSPDCL has not submitted any reply.

Commission’s View
The Commission has noted the objection on delayed replacement of burnt/ damaged
transformers by CSPDCL. CSPDCL is directed to replace such transformers as per
the timelines specified in the Standard of Performance Regulations. However, the
consumers also have the obligation to clear their dues as per the bills raised by
CSPDCL.

2.5.44 Temporary Connections to Agriculture Consumers


The Objector submitted that large number of consumers are waiting since long to get
the permanent connection from CSPDCL and have no choice other than to avail
Temporary Supply. Hence, CSPDCL should be directed to prepare time-bound plan
for release of pending Agriculture connections to farmers.

Petitioner’s Reply
CSPDCL has not submitted any reply.

Commission’s View
The Commission has noted the objection on delay in releasing new connections to
Agriculture consumers by CSPDCL. CSPDCL is directed to release the new
connections as per the timelines specified in the Standard of Performance
Regulations.

CSERC Tariff Order FY 2023-24 45


3 DETERMINATION OF INPUT COAL PRICE AT GARE PALMA-III MINE
END FOR ABVTPS

3.1 Background
CSPGCL has submitted the Petition for True up of the capital cost as well as
determination of the input price of coal from Gare Palma-III (GP-III) mine for FY
2021-22. CSPGCL has submitted details of its actual expenses incurred during the
year under various heads, viz., O&M expenses, depreciation, interest on loans,
interest on working capital, etc., and the total input price of coal as per the CSERC
MYT Regulations, 2021.
Regulation 5.9 and Regulation 49 of the CSERC MYT Regulations, 2021 specifies as
under:
“5.9. …. In respect of Integrated mine, the generating company shall file
separate mine wise petition for determination of input price of coal from such
mine.”
“49. Input Price of coal and lignite for energy charges:
49.1. Where the generating company has the arrangement for supply of coal
from the integrated mine(s) allocated to it, for use in one or more of its
generating stations as end use, partially or fulIy, the energy charge
component of tariff of the generating station shall be determined based on the
input price of coal, as the case may be, from such integrated mines determined
in accordance with these regulations.”
In accordance with the above Regulations, in the present Order, the Commission has
carried out the true up of the capital cost and also determined the Input Price of coal
from GP-III coal mine for FY 2021-22 based on the submission by CSPGCL as
discussed in the subsequent sections of this Order.

3.1.1 Allocation of Gare Palma-III Coal Mine


CSPGCL submitted that initially, the Parsa coal block was allotted to the erstwhile
CSEB and subsequently to CSPGCL for ABVTPP. The Gare Palma-III (GP-III) coal
block was allotted to M/s Goa Industrial Development Corporation (GIDC) vide letter
No. 38039/14/2008 CA-I dated November 12, 2008 by the Ministry of Coal, GOI.
GIDC, in terms of the provisions of Rule 22(4) of the Mines and Mineral Concession
Rules, 1960 as amended from time to time, prepared the Mining Plan for GP-III mine.
The Mining Plan for GP-III mine was approved by the Ministry of Coal, GOI vide
letter No. 13016/57/2009 CA-I dated May 17, 2010. Further, the approval for Mining
Lease was accorded by the GOI in terms of the provisions of Section 5(1) and Section
6(1) of the Mines and Mineral (Development and Regulation) Act, 1957 vide letter
No.13016/57/2009- CA-I dated May 30, 2011.
The Hon‟ble Supreme Court vide its Order dated September 24, 2014, cancelled the
allocation of 218 no. of coal blocks. In light of the aforesaid Order, the Parsa coal
block was deallocated from CSPGCL and the Gare Palma III coal block was
deallocated from GIDC.
Subsequently, after enactment of the Coal Mine (Special Provisions) Act, 2015, the
GP-III coal block was classified under Schedule I of the said Act. In terms of the

46 CSERC Tariff Order FY 2023-24


provisions of Section 5 of the said Act, the GP-III coal block was allocated to
CSPGCL for utilization of coal in end-use plant of ABVTPP.
In terms of Section 8 of the Coal Mine (Special Provisions) Act, 2015 and Clause (c)
of Sub Rule (2) of Rule 7 and Sub-Rule (1) of Rule 13 of the Coal Mine (Special
Provisions) Rule, 2014, the Nominated Authority issued the Allotment Order (Order
No. 103/23/2015/NA) dated September 14, 2015 for allotment of the GP-III coal
block to CSPGCL.
In terms of Section 8 of the Coal Mine (Special Provisions) Act, 2015, all the
statutory permits and approvals accorded to prior allotee were transferred to
CSPGCL.
The brief description of the GP-III coal block is tabulated below:
Table 3-1: Brief Description of GP-III Coal Block
Name of Coal Mine Gare Palma Sector III
Latitude 22010‟24.36” N to 22011‟15.84” N
Longitude 83027‟26.62” E to 83031‟56.85” E
Coalfield Mand Raigarh
Villages Bajarmuda, Dholnara
District Raigarh
State Chhattisgarh
Lease hold land for mining (Private) 444.58 (Hectares)
Lease hold land for compensatory 400 (Hectares)
afforestation (Government)

Through transparent open competitive bidding, CSPGCL appointed Gare Palma III
Collieries Limited as the Mine Development Operator (MDO). Crushing and the mine
end transportation (Surface Transportation Charges or STC in the Coal India
parlance) is also in the MDO scope. The production from the GP-III mine commenced
in December 2019 and since then mining progress has been better than the Mine Plan
benchmarks. As per Section 61 of the Act, the Regulations notified by the Central
Electricity Regulatory Commission (CERC) are one of the guiding principles for
framing of Regulations by the State Electricity Regulatory Commission‟s (SERCs).
For determination of Input Price from an integrated mine, certain provisions were
included in the draft CERC Tariff Regulations, 2019. However, considering various
suggestions, the same could not find place in the final Regulations. Provisionally, the
generating plants were allowed to bill the coal from integrated mines at the notified
rates of Coal India Ltd. The Regulation was finally notified vide second amendment
to CERC Tariff Regulations, 2019. In the State of Chhattisgarh, the provisions for
determination of input cost of coal were first notified in the MYT Regulations 2021.
For the intervening period, in response to CSPGCL request for guidance related to
billing of ECR / FCA for power generated by coal received from GP III mine, in line

CSERC Tariff Order FY 2023-24 47


with the principle adopted by the CERC, the Commission vide letter dated January
27, 2020, directed CSPGCL to provisionally bill the coal from integrated mines of
GP-III at the notified rates of Coal India Ltd. During FY 2021-22, billing continued in
accordance to the Commission‟s direction.
CSPGCL submitted that upon notification of CSERC MYT Regulations, 2021, for the
Control Period April 01, 2022 to Match 31, 2025, CSPGCL filed Petition for
determination of ARR for its conventional Power Plants, which got registered as
Petition No. 01 of 2022 (T). The Petition included prayer with detailed submissions
for approval of input cost of coal from the integrated mine Gare Palma – III (GP III)
along with detailed submission on capital cost of the GP III mine. The Commission,
allowed the capital cost of the mine and input cost of coal for the current Control
Period vide the MYT Order.

3.1.2 Date of Commercial Operation for GP-III mine


CSPGCL submitted that regarding the Date of Commercial Operation (COD) of the
integrated mines, Regulation 3.19 (iii) of the CSERC MYT Regulations, 2021
specifies as under:
“3.19. "Date of Commercial Operation" or "COD" means …. (iii) The date of
commercial operation in case of integrated mine(s), shall mean the earliest of

a) the first date of the year succeeding the year in which 25% of the Peak
Rated Capacity as per the Mining Plan is achieved; or
b) the first date of the year succeeding the year in which the value of
production estimated in accordance with these regulations, exceeds total
expenditure up to that year; or
c) the date of two years from the date of commencement of production:”
During FY 2020-21, the production from the mine crossed 1.6 MTPA. As the peak
rated capacity of the mine as per the approved mining plan is 5 MTPA, the first
conditionality of provisions of Regulation 3.19 (iii) of the CSERC MYT Regulations,
2021 was met in FY 2020-21. Accordingly, as per the CSERC MYT Regulations,
2021, the COD of the mine is April 1, 2021. The Commission has approved the same
in the MYT Order dated April 13, 2022 in Petition No. 1 of 2022. Thus, FY 2021-22
was first full year of operation of the mine after the achievement of COD.

Commission’s View
The Commission in the MYT Order dated April 13, 2022 in Petition No. 1 of 2022
had observed that the peak rated capacity of GP-III mine, as per the approved mining
plan, is 5 MTPA and the production from the GP-III mine had crossed 1.6 MTPA
during FY 2020-21. Thus, the first conditionality of COD as per Regulation 3.19 (iii)
of the CSERC MYT Regulations, 2021 was met in FY 2020-21. Accordingly, the
Commission had accepted the COD of GP-III mine as April 1, 2021 in the MYT

48 CSERC Tariff Order FY 2023-24


Order dated April 13, 2022 in Petition No. 1 of 2022. For this Order also, the
Commission has considered the COD of GP-III mine as April 1, 2021.

3.1.3 Provisions of Regulations


CSPGCL’s Submission:
CSPGCL submitted that Regulation 49.3 of the CSERC MYT Regulations 2021,
which is the enabling provision for true up is as under:
“Provided, if Commercial operation date of any integrated mine occurred
before the notification of these regulations, input price of the coal supplied
from such mine shall also be determined by the Commission as per provisions
of these regulations.”
Accordingly, for preparation of True up Petition for GP-III coal mine for FY 2021-22,
the provisions of Chapter 5 of the CSERC MYT Regulations 2021 have been
followed.
CSPGCL also submitted that the Regulations provide that the excess or short recovery
due to difference between the input price of coal determined under these Regulations
and the input price of coal adopted prior to such determination, shall be a pass through
with interest rate considered for Working Capital Loan. Therefore, in the True up
Petition, the input cost derived on the basis of referred Regulations has been used for
computation of actual fuel cost and ARR of CSPGCL plants (namely ABVTPS and
DSPM TPS) which used the coal from the GP-III coal mine.

Commission’s View
Regulation 49.2 to Regulation 49.5 of the CSERC MYT Regulations, 2021 are
reproduced below:
“49.2. The generating company shall, after the date of commercial operation
of the integrated mine(s) till the input price of coal is determined by the
Commission under these regulations, adopt the notified price of Coal India
Limited commensurate with the grade of the coal from the integrated mine(s)
or the estimated price available in the investment approval, whichever is
lower, as the input price of coal for the generating station:
49.3. Provided, if Commercial operation date of any integrated mine occurred
before the notification of these regulations, input price of the coal supplied
from such mine shall also be determined by the Commission as per provisions
of these regulations.
49.4. Provided further that the difference between the input price of coal
determined under these regulations and the input price of coal so adopted
prior to such determination, for the quantity of coal billed, shall be adjusted in
accordance with Regulation 46.3.
49.5. In case of excess or short recovery of input price under regulations 46.2
of this Regulation, the generating company shall refund the excess amount or
recover the shortfall amount, as the case may be, with simple rate of interest,
equal to the rate equal to the rate as allowed for computation of Interest on

CSERC Tariff Order FY 2023-24 49


Working Capital Loan for the said year in installment as may be decided by
the Commission.”
The COD of GP-III mine is on April 01, 2021, which is before the notification of
CSERC MYT Regulations, 2021. As per Regulation 49.3 of the CSERC MYT
Regulations 2021, the input price of coal from GP-III mine shall be determined by the
Commission. The Commission has determined the input price of coal from GP-III
mine for the first time in the MYT Order dated April 13, 2022 in Petition No. 1 of
2022 for the period FY 2022-23 to FY 2024-25. The input price of coal from GP-III
mine has not been determined by the Commission earlier for FY 2021-22. As per the
Commission‟s letter dated January 27, 2020, CSPGCL had provisionally considered
the notified price of Coal India Limited commensurate with the grade of the coal from
GP-III mine as the input price of coal for the CSPGCL plants consuming coal from
GP-III mine. In this Order, the Commission has carried out True up of input price of
coal from GP-III mine along with approval of capital cost of GP-III mine for FY
2021-22. The trued-up input price of coal from GP-III mine for FY 2021-22 has been
considered as the cost of coal for CSPGCL plants consuming coal from GP-III mine
for the purpose of truing up of FY 2021-22.

3.2 Capital Cost


CSPGCL’s submission
CSPGCL submitted that the Commission, in the MYT Order dated April 13, 2022 in
Petition No. 1 of 2022 had approved the capital cost of GP-III mine on provisional
basis, as shown in the Table below:
Table 3-2: Capital Cost for GP-III mines approved by Commission in MYT
Order dated April 13, 2022 in Petition No. 1 of 2022 on provisional basis (Rs.
Crore)
Sr. Approved Year
Particulars
No. Cost
A Statutory Expenses
1 Upfront amount paid to Ministry of Coal 39.94 COD
2 Fixed cost (Consents Cost+ Cost of Geological Report) 30.99 COD
3 Incremental cost of Geological Report 1.96 COD
4 Mining Lease agreement 21.48 COD
5 Compensation for obtaining surface right of Private land 190.14 COD
6 Addl. Compensation for private and forest land due to COD
3.44
land diversion and having Van Adhikar Patta
7 Afforestation Charges for diversion of forest land. 2.05 COD
8 Reimbursement of GIDC claim for tree felling 1.20 COD
9 Dead rent 0.09 COD

50 CSERC Tariff Order FY 2023-24


Sr. Approved Year
Particulars
No. Cost
B Other expenses
10 Payment towards Consultancy fee, BG charges to Bank, COD
Hiring of vehicles, Office rent, deployment of
9.03
manpower, Annual watch ward of office & rest house,
and other A & G expenses
11 Salaries Coal project 4.79 COD
12 FDR Expenses 110.20 COD
Total Expenses Incurred 415.31
13 Adjustment -30.92 COD
Net Expenses Incurred 384.39
C Expenses to be incurred
14 Payment of compensation of land for obtaining surface FY 21-22
415.03
right of remaining one village Bajarmuda
15 Payment of compensation of land adjacent to main road FY 22-23
5.99
of village Dholnara & Milupara.
16 Land acquisition of village Bhalumar for R&R of FY 22-23
12.64
project affected families of village Bajarmuda.
17 Rerouting of Spur line (Railway Line) passing through FY 21-22
53.45
GP-III coal mine
18 Drilling of boreholes and preparation of GR for proving
coal reserve in mining lease area and unexplored 59.431 25.60
Ha on western part of GPIII coal mine.
19 Construction of Rest house, office building and other FY 23-24
4.39
works
20 Construction of Approach Road from Gharghoda - FY 23-24
Chhal Main Road to Ghargoda Railway Siding for 2.65
transportation of Coal of GP-III Coal Block.
Expenses to be incurred 519.75
Grand Total 904.10
21 Contingency @5% of IA Cost 0.00 Reserve
22 Notional IDC 111.91
Total Capital Cost 1016.05
23 De-capitalization on achieving peak rated capacity -110.20 FY 24-25
Net Capital Cost 905.85

CSERC Tariff Order FY 2023-24 51


In the above, Rs. 25.60 Crore appearing at Sr. No. 18 towards drilling of boreholes
and preparation of GR for proving coal reserve in mining lease area and unexplored
59.431 Hectare on western part of GP-III coal mine was not considered as a part of
the capital cost for GP-III mine, as these expenses relate to unexplored area. Hence
the approved capital cost for the project stands at Rs. 880.25 Crore along with
contingency reserve of 5% (about Rs. 44 Crore). Against the above capital cost
considered in the MYT Order dated April 13, 2022 in Petition No. 1 of 2022, the
actual capital cost as per Audited Accounts for FY 2021-22, certified by the Statutory
Auditors is as under:
Table 3-3: Actual Capital Cost for GP-III mines based on Audited Accounts of
FY 2021-22 vis-a-vis Approved Capital Cost in MYT Order dated April 13, 2022,
as submitted by CSPGCL (Rs. Crore)
Sr.
Particulars Approved Actual
No.
1 Upfront amount paid to Ministry of Coal 39.94 39.94
2 Fixed cost (Consents Cost+ Cost of Geological
30.99 31.00
Report)
3 Incremental cost of Geological Report 1.96 1.96
4 Mining Lease agreement 21.48 21.48
5 Compensation for obtaining surface right of Private
190.14 190.14
land
6 Addl. Compensation for private and forest land due to
3.44 3.02
land diversion and having Van Adhikar Patta
7 Afforestation Charges for diversion of forest land. 2.05 2.05
8 Reimbursement of GIDC claim for tree felling 1.20 1.20
9 Dead rent 0.09 0.09
10 IEDC including consultancy fee, BG charges to
Bank, hiring of vehicles, office rent, deployment of 9.03 20.30
manpower, watch &ward and other such expenses.
11 Salaries Coal project (1.27 Cr in FY 16-17 & 3.52 Cr 4.79
4.79
in FY 17-18)
12 FDR Expenses 110.20 110.20
13 Adjustment -30.92 -38.97
14 IDC 111.91 111.21
Net GFA on COD 496.30 498.43
Expenses Incurred in FY 21-22
15 Payment of compensation of land for obtaining
415.03 387.28
surface right of remaining one village Bajarmuda
16 Balance for Van Adhikar Patta (SN 6 above) 0 0.41
17 Rerouting of Spur line (Railway Line) passing
53.45 0
through GP-III coal mine
18 One Time Settlement payment to PAPs in lieu of
employment 0 5.78
19 Prior Period Salary Capitalisation 0 5.56

52 CSERC Tariff Order FY 2023-24


Sr.
Particulars Approved Actual
No.
20 Construction of Approach Road from Gharghoda -
0 1.33
Chhal Main Road to Ghargoda Railway Siding
21 Other Miscellaneous / Contingent expenses 0 0.45
Sub-Total for FY 21-22 468.48 400.80
Closing GFA for FY 21-22 964.78 899.24

CSPGCL further submitted that:


a. The Incidental expenditure during construction (IEDC) expenses include Salary
expense capitalized on COD in Gare Palma accounts for FY 2019-20 (Rs. 2.39
Crore) and FY 2020-21 (Rs. 5.06 Crore) and capitalization of R&M expenses and
A&G expenses of Rs. 2.25 Crore capitalized on COD.
b. Though the accounts reflect the total payment of one Time Settlement payment to
Project Affected Persons (PAPs) as Rs. 11.75 Crore, only 50% of the amount has
been considered here.
c. The construction of kuchha approach road from Gharghoda - Chhal Main Road to
Ghargoda Railway Siding was a work undertaken due to urgency and may be
considered as part of Contingency work.
d. As on COD, the total CWIP was about Rs. 0.73 Crore.
In response to queries raised during TVS, vide additional submission dated February
3, 2023 CSPGCL revised the Adjustment figure of Rs. 38.97 Crore to Rs 41.98 Crore.
After prudence check, For the purpose of this Order, Commission has relied on the
same. CSPGCL submitted that as on COD, there is marginal (less than 0.5%) increase
in the estimated cost and the closing GFA for FY 2021-22 is lower than the estimate.
The total contingency expenses are also lower than the approved ceiling of 5% of
capital cost. Also, there is slight reduction in the IDC being submitted now compared
to the IDC submitted earlier due to minor adjustment of actual quarter-wise expenses.
CSPGCL submitted that during FY 2021-22, CSPGCL has tied up and drawn actual
loan, however, the actual loan drawal is lower than 70% of the capital cost. Thus, the
equity deployed is more than the normative ceiling of 30% of capital cost. Hence,
CSPGCL has considered the normative debt equity ratio of 70:30 for FY 2021-22.
CSPGCL further submitted that a large part of project expenses pertains to
compensation for land. The land acquisition has been made and compensation has
been paid in accordance with the Orders of the revenue authorities. In this regard, the
Government of Chhattisgarh, Energy Department vide letter no. 2647/ R-
124/2019/13/2 dated 18.11.2019 had directed CSPGCL to obtain approval of this
Commission for the compensation to be paid for land before making payment.
CSPGCL had approached the Commission vide letter no. 03-09/Reg-2/49 dated
20/10/2020 to grant in-principle approval for the compensation to be paid towards
land. In response, the Commission vide letter no. 13-GH30/ 2020/186 dated
27.01.2020 replied that the matter of approval of rate of compensation to be paid to
the land owners does not come under the jurisdiction of the Commission. The relevant
extract is reproduced below:

CSERC Tariff Order FY 2023-24 53


“……The said provisions do not contain any reference to approval of the rate
of compensation to be paid for land acquisition by the generating company.
Thus, the matter of approval of the rate of compensation to the landowners for
operating/ commissioning the coal mines sanctioned in Gare Palma- 3 does
not come under the purview of Section 86 of the Electricity Act, 2003”
………………………………..
“…… In the light of the aforesaid, the Commission is of the view that the
matter does not require approval of the Commission.” (Emphasis added)
Accordingly, the compensation for land has been paid as per the Government
directive. CSPGCL requested the Commission to accept the same as uncontrollable
expense for CSPGCL.
CSPGCL submitted that the Commission vide its letter no. 13-GH30/ 2020/186 dated
27.01.2020, had provisionally permitted CSPGCL to continue to adopt the notified
price of Coal India Limited commensurate with the grade of coal from integrated
mines. Accordingly, CSPGCL had adopted the South Eastern Coalfields Ltd. (SECL)
rates till COD of the mine. While ascertaining the capital cost of the mine, it is
necessary to set off or adjust the revenue earned over and above the expenses incurred
for coal production before COD of a mine. This treatment is similar to setting off of
revenue earned due to sale of infirm power from capital cost of a power plant before
COD. Accordingly, CSPGCL considered the quantity already submitted to this
Commission through FCA, which is RR (Railway receipt) quantity. During the
previous submission of capital cost in Petition No. 1 of 2022, for provisional working
of the adjustment value, a normative transit loss segregated in 50:50 ratio between the
rail and road transport was considered. The statutory charges payable prior to COD
were also computed on the basis of RR quantity grossed up by transit loss of 0.4% in
road transport. However, CSPGCL in Petition No. 1 of 2022 had submitted that these
charges are subject to change once the final reconciliation of quantity supplied from
GP-III mine to ABVTPP, Marwa is completed. At present, as the transit passes data
have been compiled and as after FY 2020-21, the plant end transit loss data has
attained finality, in this Petition for true up of FY 2021-22, the final adjustment
computation has been submitted.
CSPGCL submitted that save for some uncontrollable reason (including but not
limited to some legal/ statutory development), the capital cost on COD need not be
revised again. The other costs incurred during the period are also known, hence,
CSPGCL has considered the actual values for true up of FY 2021-22. The statutory
charges have been computed on the basis of actual grade-wise quantity dispatched (as
recorded in the transit passes). The adjustment value, which was earlier estimated as
Rs. 30.92 Crore, has been revised to Rs. 38.97 Crore based on actual data.
Accordingly, in line with regulatory principles, CSPGCL has reduced this amount
from the capital cost incurred on COD and the input price of coal has been worked out
considering the reduced capital cost. CSPGCL submitted that the set off considered
for determination of input price of coal is for regulatory purpose only, which is
different from accounting principles. The accounting principles follow the concept of
moving averages (which involves loading of stock cost) and regulatory approach
relies on replacement cost philosophy. It is for this reason that since the start of plant-
wise two-part tariff regime, there has always been a difference between the cost of
coal in the financial accounts and the regulatory accounts. In this case too, the

54 CSERC Tariff Order FY 2023-24


adjustment in accounts include stock valuation. However, for regulatory purpose, as
cost of coal is recovered only when electricity is supplied, historically, stock valuation
finds no place in the Commission‟s Orders. Accordingly, CSPGCL has relied on the
principle approved in the previous Orders of the Commission.
CSPGCL further submitted that at this juncture, there exist some unsettled contingent
contractual / legal issues, which may have commercial implications. Some such
disputes are already before arbitration and some others are at discussion stage. Details
of such issues were submitted during the proceedings on Petition No. 01 of 2022 and
the Commission had taken cognizance of such issues in the MYT Order dated April
13, 2022. Though such issues may not have an impact on true up of FY 2021-22,
CSPGCL submitted brief updates on such issues, as under.
a. Claim before the Tribunal by the previous coal mine allottee, i.e., M/s Goa
Industrial Development Corporation (GIDC): M/s GIDC has lodged a claim of
Rs. 232.06 Crore before the Hon‟ble Tribunal at Bilaspur (CG) constituted under
the Coal Bearing Act. No further development has taken place. CSPGCL
submitted that in case any cost is borne by CSPGCL in future, the same will be
submitted.
b. Payment against demand received from Chhattisgarh Environment Control Board
(CECB), citing conditions of environment clearance: The matter is before
arbitration to adjudge the issue regarding the liability of CSPGCL vis-a-vis the
MDO.
c. Payment against 600 metre Coal Transport Road constructed by M/s. Gare Palma
Collieries Limited and proposal of another 950 metre road: The matter is before
the Joint Committee for amicable settlement.
d. Railway Siding expenses at Mine end: On the basis of Feasibility Survey Report
(FSR) prepared by M/s RITES in December 2017, the cost of the Railway Siding
was estimated to be Rs. 60 Crore. However, now M/s IRCON (A Government of
India Undertaking) has been appointed for the said work and a MOU has been
entered between the Parties for the same. The revised cost estimate will be known
after receipt of DPR. However as per MOU, till such time the estimate for the
Railway siding is being considered as Rs. 75 Crore (excluding value of land,
taxes and duties).
e. Arbitration cases with the MDO: Such arbitrations relate to unloading charges at
plant end, liability for one-time settlement of Project Affected Persons (about
1090 persons), settlement of environment clearance issues, etc. The cases are yet
to be decided and the principal amount involved is now estimated to be over Rs.
100 Crore.
CSPGCL submitted that as directed by the Commission in the MYT Order dated
April 13, 2022, no claim against the above cited issues have been included in this
Petition. CSPGCL shall claim these expenses when they are actually incurred.
CSPGCL also submitted that earlier it was planned that employment will be provided
by MDO to the Project Affected Persons (PAPs). Further, rehabilitation for the
Project Affected Families (PAFs) was planned at the Village Bhalumar. Accordingly,
an estimate of about Rs. 12.64 Core was considered in the original cost estimate
approved in the MYT Order dated April 13, 2022 (Sr. No. 16 of the Table related to
approved cost break up). However, now number of PAPs are opting for one-time
CSERC Tariff Order FY 2023-24 55
settlement of compensation of Rs. 5 Lakh. Similarly, PAFs are opting for one-time
settlement. Vide letter no. 5350/LA/2022 dated 16.06.2022, the Collector of Raigarh
district has communicated that villagers of Bajarmuda and Dholnara are not willing to
get displaced to R&R village Bhalumar and for amicable settlement, the Collector of
Raigarh district has suggested one-time payment of Rs 9,55,000/- per PAF. At
present, in the interest of keeping the mine operational, CSPGCL and MDO have
agreed to pay costs in the 50:50 ratio. Accordingly, first tranche payment of Rs. 11.55
Crore has already been deposited to revenue authorities. The district authorities have
been requested to certify the number of PAFs and PAPs. CSPGCL submitted that in
view of Government Policy, decisions of the revenue authorities, and outcome of
arbitration decisions, the project cost may escalate substantially. However, except the
50% share of Rs. 11.55 Crore already paid, CSPGCL has not included any other cost
in the true up petition.

Commission’s View
As regards the Capital Cost for integrated mine, Regulation 55 of the CSERC MYT
Regulations, 2021 specifies as under:
“55. Capital Cost:
55.1. The expenditure incurred, including IDC and IEDC, duly certified by the
Chartered Accountant, for development of the integrated mine(s) up to the
date of commercial operation, shall be considered for arriving at the capital
cost.
55.2. Capital expenditure incurred shall be admitted by the Commission after
prudence check.
55.3. Capital expenditure incurred on infrastructure for crushing,
transportation, handling, washing and other mining activities required for
mining operations shall be arrived at separately in accordance with these
regulations:
Provided that where crushing, transportation, handling or washing are
undertaken by the generating company, the expenditure incurred on
infrastructures of these components shall be capitalized;
Provided further that where mine development and operation, with or without
any component of crushing, transportation, handling or washing are
undertaken by the generating company by engaging Mine Developer and
Operator or an agency other than Mine Developer and Operator, the capital
expenditure incurred by Mine Developer and Operator or such agency shall
not be capitalised by the generating company and shall not be considered for
the determination of input price.
55.4. The capital expenditure shall be determined by considering, but not
limited to, the Mining Plan, detailed project report, mine closure plan, cost
audit report and such other details as deemed fit by the Commission.
55.5. In case of integrated mine(s) which have declared the date of
commercial operation prior to 1.4.2022, the capital expenditure allowed by
the Commission for the period ending 31.3.2022 as per provisions of these
regulations shall form the basis for computation of input price.”

56 CSERC Tariff Order FY 2023-24


In view of the above Regulations, the Commission has undertaken the true up of the
Capital Cost for GP-III coal mine as discussed below.
As per Regulation 55.1, the expenditure incurred including IDC and IEDC, duly
certified by the Chartered Accountant, for development of the integrated mine(s) up to
the date of commercial operation, shall be considered for arriving at the capital cost.
Therefore, the Commission has considered the expenditure incurred, including IEDC,
duly certified by the Chartered Accountant, for development of the integrated mine(s)
up to the COD for GP-III mine for approval purpose. As the IDC is computed in
accordance with Regulatory principles, hence, for the purpose of IDC, Commission
has adopted the methodology settled in the previous order.
The Commission had considered the capital cost of GP-III mine as on April 01, 2021
(COD) on provisional basis in the MYT Order dated April 13, 2022 in Petition No. 1
of 2022. Except for IEDC, IDC and regulatory adjustment, values of all other items
claimed by CSPGCL are at the same level as approved provisionally in the MYT
Order dated April 13, 2022. Therefore, the Commission has accepted the actual
expenses incurred as on March 31, 2021 pertaining to upfront payment paid to
Ministry of Coal, fixed cost (consents cost and cost of geological report), incremental
cost of geological report, mining lease agreement, compensation for obtaining surface
right of private land, afforestation charges for diversion of forest land, reimbursement
of GIDC claim for tree felling, dead rent, salaries of coal project, and FDR expenses.
CSPGCL has submitted some variation in the capital cost as on COD, as discussed
below:
Incidental Expenses During Construction (IEDC)
The Commission had considered IEDC of Rs. 9.03 Crore in the capital cost approved
provisionally in the MYT Order dated April 13, 2022. For True up of FY 2021-22,
CSPGCL has claimed IEDC of Rs. 20.30 Crore. In support of the capital cost with
IEDC, CSPGCL has submitted a Chartered Accountant (CA) certificate, wherein the
IEDC mentioned was Rs. 20.99 Crore. CSPGCL submitted that the CA certificate
pertains to the capex incurred for the project and the reconciliation of IEDC as under:
Table 3-4: IEDC expenses as on CoD (Rs. Crore)
Sr.
Particulars Amount
No.
1 IEDC as per CA Certificate 20.99
2 Less: CWIP as on 01.04.2021 (0.73)
3 Add: Furniture and Office equipment 0.05
4 IEDC claimed in True up Petition 20.30
*The minor difference of Rs. 0.01 Crore is due to rounding off of values
Considering the above reconciliation, the Commission allows the IEDC of Rs. 20.30
Crore as part of capital cost as on COD.

Adjustment of additional revenue


During the period before COD, the Commission had permitted CSPGCL to
provisionally continue to adopt the notified price of Coal India Ltd. CSPGCL has
adjusted the additional revenue of Rs. 38.97 Crore earned over and above the actual

CSERC Tariff Order FY 2023-24 57


expenses towards coal production from the Capital Cost in a manner similar to that of
infirm power.
Subsequently, CSPGCL in its additional submission submitted that inadvertently in
the computation of gain from transfer of coal before COD, the GST on FRV, which
was claimed @ 18% was already claimed during the true-up of FY 2020-21 as it was
paid from the Central Accounting Unit. Therefore, the additional revenue claim was
revised to Rs. 41.98 Crore.
Accordingly, the Commission has adjusted the additional revenue of Rs. 41.98 Crore
from the Capital Cost under the head of adjustment.
Interest During Construction (IDC)
The Commission had considered IDC of Rs. 111.91 Crore in the capital cost approved
provisionally in the MYT Order dated April 13, 2022. For True up of FY 2021-22, the
IDC has been revised due to minor adjustment in actual quarter-wise expenses.
However, CSPGCL had claimed IDC in accordance with Hon‟ble ATE Judgment in
Appeal No 231 of 2017 dated October 3, 2019, wherein the Hon‟ble ATE had ruled
that in absence of actual loan, the developer is entitled to normative IDC. In
accordance with the ATE Judgment, the Commission had considered IDC as part of
capital cost approved provisionally in the MYT Order dated April 13, 2022. The
Commission asked CSPGCL about the interest rates considered for calculation of
IDC. CSPGCL submitted that the expense on GP-III mine started from FY 2015-16.
CSPGCL has used the trued up weighted average interest rates of CSPGCL from FY
2015-16 to FY 2020-21, as per the Truing up Orders to determine IDC. The
computation has been shared by CSPGCL as part of financial model and is found to
be in order. Accordingly, the Commission allows the revised IDC as part of capital
cost as on COD.
Capitalisation in FY 2021-22
Regulation 56.1 of the CSERC MYT Regulations, 2021 specifies the conditions
whereby the expenditure incurred shall be considered as Additional Capital
Expenditure, as reproduced below:
“56.1 The expenditure, in respect of the integrated mine(s), incurred or
projected to be incurred after the date of commercial operation and up to the
date of achieving the Peak Rated Capacity may be admitted by the
Commission, subject to prudence check and shall be capitalized in the
respective year of the tariff period as additional capital expenditure
corresponding to the Annual Target Quantity of the year as specified in the
Mining Plan or actual extraction in that year, whichever is higher, on
following counts:
(a) expenditure incurred on activities as per the Mining Plan;
(b) expenditure for works deferred for execution and un-discharged
liabilities recognized for works executed prior to date of commercial
operation;
(c) expenditure for works required to be carried out for complying
with directions or orders of any statutory authorities;
(d) liabilities arising out of compliance of order or decree of any court
of law or award of arbitration;

58 CSERC Tariff Order FY 2023-24


(e) expenditure for procurement and development of land (including
but not limited to expenditure incurred on R&R of land oustees) as per
the Mining Plan;
(f) expenditure for procurement of additional heavy earth moving
machineries for replacement, on completion of their useful life; and
(g) liabilities due to Change in Law or Force Majeure events in order
to mitigate threat to life and property;
Provided that in case of replacement of any assets, the additional
capitalization shall be worked out after adjusting the gross fixed assets and
cumulative depreciation of the assets replaced on account of de-
capitalization:
Provided further that the generating company shall prepare guidelines for
procurement and replacement of heavy mining equipment such as Healy Earth
Moving Machineries and share the same with the beneficiaries and submit it
to the Commission along with its petition.”
Although the above Regulation applies to the Control Period from FY 2022-23 to FY
2024-25, the Commission has carried out prudence check of capitalisation made in
FY 2021-22 as per the above principles.
Payment of compensation of land for obtaining surface right of remaining one
village Bajarmuda
CSPGCL submitted that a large part of project expenses pertains to compensation for
land. The land acquisition has been made and compensation has been paid in
accordance with the Orders of the revenue authorities. The Government of
Chhattisgarh, Energy Department vide its letter no. 2647/ R-124/2019/13/2 dated
18.11.2019 had directed CSPGCL to obtain approval of the Commission for the
compensation to be paid for land before making such payment. Accordingly,
CSPGCL approached the Commission vide letter no. 03-09/Reg-2/49 dated
20/10/2020 to grant in-principle approval for the compensation to be paid towards
land. In response, the Commission vide letter no. 13-GH30/ 2020/186 dated
27.01.2020 replied that the matter of approval of rate of compensation to be paid to
the land owners does not come under the jurisdiction of the Commission.
Accordingly, the land compensation has been paid as per the Government directive.
The Commission had provisionally approved Rs. 415.03 Crore towards Payment of
compensation of land for obtaining surface right of remaining one village Bajarmuda
in the MYT Order dated April 13, 2022 in Petition No. 1 of 2022. However, CSPGCL
has claimed Rs. 387.28 Crore towards the same for True up of FY 2021-22. As per
Regulation 56.1(e) above, expenditure for procurement and development of land
(including but not limited to expenditure incurred on R&R of land oustees) is
allowable as Additional Capital Expenditure. Based on the CA certificate submitted
by CSPGCL, the Commission approves the capitalisation of Rs. 387.28 Crore in FY
2021-22.
One-Time Settlement towards payment to Project Affected Persons (PAPs)
CSPGCL submitted that earlier it was planned that employment will be provided by
MDO to the PAPs. Further, rehabilitation for the Project Affected Families (PAFs)
was planned at the Village Bhalumar. Accordingly, estimate of about Rs 12.64 Crore
was considered in the original cost estimate. However, now a number of PAPs are

CSERC Tariff Order FY 2023-24 59


opting for one-time settlement of compensation of Rs. 5 Lakh. Similarly, PAFs are
opting for one-time settlement. Vide letter no 5350/LA/2022 dt. 16.06.2022, the
Collector of Raigarh district has communicated that villagers of Bajarmuda and
Dholnara are not willing to get displaced to R&R village of Bhalumar and for
amicable settlement the Collector has suggested onetime payment of Rs 9,55,000/- per
PAF. At present, CSPGCL and MDO have agreed to pay costs in the 50:50 ratio.
Accordingly, first tranche payment of Rs. 11.55 Crore has already been deposited
with revenue authorities. The district authorities have been requested by CSPGCL to
certify the number of PAFs and PAPs. CSPGCL has claimed 50% of the amount
already incurred by it as capitalisation in FY 2021-22. As per Regulation 56.1(e)
above, expenditure for procurement and development of land (including but not
limited to expenditure incurred on R&R of land oustees) is allowable as Additional
Capital Expenditure. The Commission asked CSPGCL to provide copies of Orders or
communications regarding compensation or rehabilitation of PAPs and PAFs.
CSPGCL in its reply submitted the copy of the letter from Collector, Raigarh district
and the arrangement between CSPGCL and MDO for sharing the cost of R&R of
PAPs and PAFs. Based on the above, the Commission allows the amount of Rs. 5.78
Crore as capitalisation in FY 2021-22.
Prior Period Salary Capitalisation
CSPGCL has claimed Rs. 5.56 Crore as prior period salary capitalisation in FY 2021-
22. The Commission observed that CSPGCL has claimed salary expenses as part of
IEDC in the capital cost and has also claimed prior period salary capitalisation
separately. The Commission asked for clarification from CSPGCL on this issue.
CSPGCL clarified that while IEDC includes salary expenses for FY 2019-20 and FY
2020-21, the prior period salary capitalisation pertains to salary expenses prior to FY
2019-20. Ideally all the expenses incurred up to the COD of a project is capitalised.
Since, the prior period salary claimed by CSPGCL is for the period prior to FY 2019-
20, CSPGCL should have claimed it as part of capitalisation up to COD, i.e., till FY
2020-21. However, CSPGCL has claimed the same in FY 2021-22. Keeping the
general principle of capitalisation of all expenses incurred up to COD in view, the
Commission allows the prior period salary capitalisation of Rs. 5.56 Crore as part of
capitalisation in FY 2021-22.
Construction of Approach Road from Gharghoda - Chhal Main Road to Ghargoda
Railway Siding, Balance for Van Adhikar Patta and Other Miscellaneous /
Contingent works
CSPGCL submitted that construction of approach road from Gharghoda - Chhal
Main Road to Ghargoda Railway Siding was a work undertaken due to urgency and
may be considered as contingent work. The total contingency expenses are far lower
than the approved capping of 5% of capital cost. The Commission in the MYT Order
dated April 13, 2022 had allowed a provision of contingency expense upto 5% of the
capital cost of GP-III mine, considering the first of its kind project and uncertainties
involved in such large projects. Accordingly, the Commission allows the expenses
towards construction of approach road from Gharghoda - Chhal Main Road to
Ghargoda Railway Siding and other miscellaneous / contingent works as
capitalisation in FY 2021-22. Further, the balance amount of Rs. 0.41 Crore paid
towards compensation for private and forest land due to land diversion and having
Van Adhikar Patta is allowed as capitalisation in FY 2021-22.

60 CSERC Tariff Order FY 2023-24


Based on the above, the capital cost approved by the Commission for GP-III mine for
True up of FY 2021-22 is as under:
Table 3-5: Approved Capital Cost of GP-III Mine for True up of FY 2021-22 (Rs. Crore)
MYT
SN Particulars Petition Approved
Order
1 Upfront amount paid to Ministry of Coal 39.94 39.94 39.94
2 Fixed cost (Consents Cost+ Cost of Geological
30.99 31.00 31.00
Report)
3 Incremental cost of Geological Report 1.96 1.96 1.96
4 Mining Lease agreement 21.48 21.48 21.48
5 Compensation for obtaining surface right of
190.14 190.16 190.16
Private land
6 Addl. Compensation for private and forest land
due to land diversion and having Van Adhikar 3.44 3.02 3.02
Patta
7 Afforestation Charges for diversion of forest
2.05 2.05 2.05
land.
8 Reimbursement of GIDC claim for tree felling 1.2 1.2 1.2
9 Dead rent 0.09 0.09 0.09
10 IEDC including consultancy fee, BG charges to
Bank, hiring of vehicles, office rent,
9.03 20.30 20.30
deployment of manpower, watch &ward and
other such expenses.
11 Salaries Coal project (1.27 Cr in FY 16-17 &
4.79 4.79 4.79
3.52 Cr in FY 17-18)
12 FDR Expenses 110.2 110.2 110.2
13 Adjustment -30.92 -41.98 -41.98
14 IDC 111.91 111.21 111.21
Net GFA on COD 496.30 495.42 495.42
Expenses Incurred in FY 21-22
15 Payment of compensation of land for obtaining
surface right of remaining one village 415.03 387.28 387.28
Bajarmuda
16 Balance for Van Adhikar Patta (SN 6 above) 0 0.41 0.41
17 Rerouting of Spur line (Railway Line) passing
53.45 0 0
through GP-III coal mine
18 One Time Settlement payment to PAPs in lieu
0 5.78 5.78
of employment
19 Prior Period Salary Capitalisation 0 5.56 5.56
20 Construction of Approach Road from
Gharghoda - Chhal Main Road to Ghargoda 0 1.33 1.33
Railway Siding
21 Other Miscellaneous / Contingent expenses 0 0.45 0.45
Sub Total For FY 21-22 468.48 400.80 400.80
Closing GFA for FY 21-22 964.78 896.23 896.23

CSERC Tariff Order FY 2023-24 61


Unsettled Contingent Contractual / Legal Issues
CSPGCL has submitted that there are unsettled contingent contractual / legal issues,
which may have commercial implications for capital cost of GP-III mine. Some such
disputes are already before arbitration and some others are at discussion stage.
CSPGCL has submitted the current status of these unsettled contractual and legal
issues, namely claim before the Tribunal by the previous coal mine allottee M/s
GIDC, Demand received from Chhattisgarh Environment Control Board (CECB),
citing conditions of environment clearance, payment against 600 metre Coal
Transport Road constructed by M/s. Gare Palma Collieries Limited and proposal of
another 950 metre road, Railway Siding expenses at Mine end and arbitration cases
with the MDO. At present, CSPGCL has not claimed any amount against the
unsettled issues, however depending on the outcome of these issues there may be
liabilities to be incurred by CSPGCL in future. The Commission notes the
submissions of CSPGCL and directs CSPGCL to submit the details of all additional
liabilities that will be incurred by it post resolution of unsettled issues, if any, along
with supporting documents and justification in future Tariff Petitions. The
Commission shall allow the same subject to prudence check.

Capitalisation and Closing GFA


The Capitalization and Closing GFA of GP-III mine for True up of FY 2021-22 are
shown in the following Table.
Table 3-6: Opening GFA, Capitalisation and Closing GFA for GP-III
Mines for True up of FY 2021-22 (Rs. Crore)
Particulars MYT Order Petition Approved
Opening GFA 496.30 495.42* 495.42
Capitalisation 468.48 400.81 400.81
Closing GFA 964.78 896.23 896.23
*Note: CSPGCL through its additional submission revised opening GFA

Means of Finance
As regards means of finance, the Commission notes that CSPGCL has tied up loans
for GP-III mine post COD of mine and has drawn the loans as well. However, the
loan drawal has been less than the normative level of 70% of capital cost.
Accordingly, the Commission has considered the normative debt: equity ratio of
70:30 for GP-III mines for True up of FY 2021-22.
Table 3-7: Approved Funding of Capitalisation for GP-III Mines for FY 2021-22 (Rs.
Crore)
MYT Order Petition Approved
Particulars As on COD on FY As on COD on FY As on COD on FY
April 01, 2021 2021-22 April 01, 2021 2021-22 April 01, 2021 2021-22
Equity 148.89 140.54 148.63 120.24 148.63 120.24
Debt 347.41 327.94 346.79 280.56 346.79 280.56
Total 496.30 468.48 495.42 400.80 495.42 400.80

62 CSERC Tariff Order FY 2023-24


3.3 Progress Against the Mining Plan
CSPGCL’s submission
CSPGCL submitted that the Mining Plan for the GP-III coal block was prepared by
prior allottee, i.e., M/s Goa Industrial Development Corporation and approval was
accorded to the same by Ministry of Coal, Government of India vide its letter bearing
reference number 13016/57/2009-CA-I dated May 17, 2010. The coal mine has been
allocated to CSPGCL for end use of coal at ABVTPP, Marwa. Since the beginning,
CSPGCL has been overachieving vis-à-vis almost all the performance benchmarks.
The production from mine has been higher than the targets defined in the mine plan.
Even during the COVID period, when the GoI relaxed the targets for all the mines,
CSPGCL exceeded the original targets. During FY 2021-22 too, the actual production
from mine, dispatch from mine to railway siding and loading on railway racks for
dispatch to plants, all exceeded the target of 3.5 Million Tonnes set in the mining
plan. CSPGCL further submitted that as per the CSERC MYT Regulations, 2021, the
general principles set in the Chapter 2 are applicable for the integrated mines too.
Thus, the sharing of gains/ losses as per Regulation 12 and 13 of the CSERC MYT
Regulations, 2021 is applicable to integrated mines too.

Commission’s View
The Commission sought the copy of the approved Mining Plan for GP-III coal block
from CSPGCL and validated the details of Annual Target Quantity (ATQ) as per the
Mining Plan submitted by CSPGCL.
The Commission notes the submission of CSPGCL regarding the progress against
Mining Plan and the over achievement of CSPGCL with respect to extraction of coal
from GP-III mine with respect to the ATQ as per Mining Plan and has accordingly
carried out the sharing of gains/losses as per Regulation 12 and 13 of the CSERC
MYT Regulations, 2021.

3.4 Computation of Input Price of Coal


CSPGCL’s submission
Regulation 52.1 of the CSERC MYT Regulations, 2021 specifies as under:
“52. Input Price of coal:
52.1 Input price of coal or lignite from the integrated mine(s) shall be
determined based on the following components:
I) Run of Mine (ROM) Cost; and
II) Additional charges:
a. crushing charges.
b. transportation charge within the mine up to the washery end or coal
handling plant associated with the integrated mine, as the case may be;
c. handling charges at mine end;
d. washing charges; and
e. transportation charges beyond the washery end or coal handling plant,
as the case may be, and up to the loading point:

CSERC Tariff Order FY 2023-24 63


Provided that in cases where the transportation is in two stages i.e from
mine to the storage yard and then from the yard to the plant, the
transportation charge shall imply cumulative of the two.
Provided that one or more components of additional charges may be
applicable in case of the integrated mine(s), based on the scope and nature
of the mining activities;
52.2. Statutory Charges, as applicable, shall be allowed.”
Further, Run of Mine cost of coal in case of integrated mines is to be determined as
per Regulation 53.2 of the CSERC MYT Regulations, 2021, as reproduced below:
“53.2. Run of Mine Cost of coal in case of integrated mine allocated through
allotment route under Coal Mines (Special Provisions) Act, 2015 shall be
worked out as under:
ROM Cost = [(Annual Extraction Cost / ATQ) + Mining Charge]+ (Fixed
Reserve Price).
Where,
(i) Annual Extraction Cost is the cost of extraction of coal as computed in
accordance with Regulation 36F of these regulations;
(ii) Mining Charge is the charge per tonne of coal paid by the generating
company to the Mine Developer and Operator engaged by the generating
company for mining, wherever applicable; and
(iii) Fixed Reserve Price is the fixed reserve price per tonne along with
subsequent escalation, if any, as provided in the Coal Mine Development and
Production Agreement.”
Further, Regulation 57 of the CSERC MYT Regulations, 2021 defines components of
the reproduced as below:
“57. Annual Extraction Cost: The Annual Extraction Cost of integrated
mine(s)shall consist of the following components:
(1) Depreciation;
(2) Interest on Loan;
(3) Return on Equity;
(4) O&M Expenses, excluding mining charge;
a. HR expenses
b. M&G Expenses
(5) Interest on Working Capital;
(6) Mine closure expenses, if not included in mining charge; and
(7) Statutory charges, if applicable.”
CSPGCL has accordingly computed the Annual Extraction Cost for GP-III mines as
described below.

3.4.1 Depreciation
CSPGCL’s submission
Depreciation has been calculated as per Regulation 59 of the CSERC MYT
Regulations, 2021. The depreciation rate has been computed in accordance with
64 CSERC Tariff Order FY 2023-24
Appendix 1A of the CSERC MYT Regulations, 2021. Further, as the expense
incurred on statutory compliance is in the form of FDR, which is not a depreciable
asset, no depreciation is being claimed on the same.

Commission’s View
Regulation 59 of the CSERC MYT Regulations, 2021 specifies as under:
“59. DEPRECIATION
59.1. Depreciation in respect of integrated mine(s) shall be computed from the
date of commercial operation by applying Straight Line Method
59.2. The value base for the purpose of depreciation shall be the capital cost
of the asset admitted by the Commission:
Provided that,
i) freehold land or assets purchased from grant shall not be considered as
depreciable assets and their cost shall be excluded from the capital cost while
computing depreciable value of the assets;
ii) where the allotment of freehold land is conditional and is required to be
returned, the cost of such land shall be part of value base for the purpose of
depreciation, subject to prudence check by the Commission; and
iii) lease, hold land / Intangible assets towards mining/surface rights,
associated statutory payments and Rehabilitation & Resettlement (R&R)
expenses shall be amortized over the lease period or remaining life of the
integrated mine(s), whichever is lower.
59.3. The salvage value of an asset shall be considered as 5% of the capital
cost of the asset:
Provided that the salvage value shall be:
i) zero for IT equipment and software;
ii) zero for intangible assets towards mining/surface rights, associated
statutory payments and R&R works
iii) zero or as agreed by the generating company with the State Government
for land; and
iv) as notified by the Ministry of Corporate Affairs under the Companies Act,
2013 for specialized mining equipment.
59.4. Depreciation in respect of integrated mine(s) shall be arrived at
annually by applying depreciation rates or on the basis of expected useful life
specified in Appendix 1A of these regulations:
Provided that specialized mining equipment shall be depreciated as per the
useful life and depreciation rate as notified by the Ministry of Corporate
Affairs under the Companies Act, 20l3.”
For computation of depreciation, the Commission has considered the Capital Cost as
on COD as the opening GFA for FY 2021-22. Since, FDR is not a depreciable asset,
no depreciation has been considered on the same. Addition during the year has been
worked out based on the capitalisation allowed during FY 2021-22.

CSERC Tariff Order FY 2023-24 65


As CSPGCL owns only the mining rights for the GP-III mines, the Commission has
considered the depreciation rate of 5% as specified in CSERC MYT Regulations,
2021 for Mine Development Expenses. For other assets like Kuchcha Road, Furniture
& Fixtures and Computers Hardware and Software, the applicable depreciation rates
as specified in Regulations have been considered.
The depreciation approved by the Commission for FY 2021-22 is as under:
Table 3-8: Depreciation Approved for FY 2021-22 (Rs. Crore)
Particulars Petition Approved
Opening Capital Cost 495.42 495.42
Closing Capital Cost 896.23 896.23
Average Capital Cost 695.83 695.83
Depreciable Value (100%) 585.63 585.63
Rate of Depreciation 5.13% 5.13%
Depreciation 30.05 30.05

3.4.2 Interest on Loan


CSPGCL’s submission
CSPGCL submitted that the interest on loan has been calculated on normative basis
by considering 70% of the capital cost as debt. During FY 2021-22, CSPGCL has got
loan sanctioned from the consortium of PFC and REC with both the lenders having
50% share of the amount of loan. However, as on April 1, 2021, there was no actual
loan. As per Regulation 58.4 read with the second proviso to Regulation 24.5 of the
CSERC MYT Regulations, 2021, in such case weighted average rate of interest for
the Generating Company as a whole is applicable. Accordingly, interest rate of
10.15% has been considered in the Petition. Also, as per the provisions of the CSERC
MYT Regulations, 2021, the depreciation has been considered as normative
repayment for the year.

Commission’s View
Regulation 24 and 58 of the CSERC MYT Regulations, 2021 specify the method of
computation of Interest and Finance charges for loan capital. The Commission has
considered the opening normative loan for FY 2021-22 equal to debt component
considered for capital cost as on COD. The addition of loan during FY 2021-22 has
been considered equal to debt portion of capitalised works as approved in this Order.
The loan repayment has been considered equivalent to Depreciation approved in this
Order.
As there was no actual loan as on 1st April 2021, for GP-III mine, therefore, the
Commission has accepted CSPGCL submission and considered the interest rate as the
weighted average rate of interest for the Generating Company as a whole in
accordance with Regulation 58.4 read with the second proviso to Regulation 24.5 of
CSERC MYT Regulations, 2021. Accordingly, the Commission has considered
interest rate of 10.15% for calculation of interest rate for FY 2021-22. The interest on
loan approved by the Commission for FY 2021-22 is shown in the Table below:

66 CSERC Tariff Order FY 2023-24


Table 3-9: Interest on Loan for GP-III mines approved for FY 2021-22 (Rs.
Crore)
Particulars Petition Approved
Opening Loan 346.80 346.80
Addition Due to Addnl. Capitalisation 280.56 280.56
Repayment During the Year 30.05 30.05
Average Loan 472.05 472.05
Interest Rate 10.15% 10.15%
Interest Charges 47.91 47.91
Finance Charges 0 0
Total Interest & Finance Charges 47.91 47.91

3.4.3 Return on Equity


CSPGCL’s submission
CSPGCL submitted that RoE has been calculated in terms of Regulation 23.1 read
with Regulation 17 of the CSERC MYT Regulations, 2021. The normative equity has
been considered as 30% of the capital cost and the RoE has been calculated on
average of opening and closing equity. The base rate of RoE has been considered as
14% in line with Regulation 23.1 of CSERC MYT Regulations, 2021. As per the
principle adopted by the Commission in all the previous Orders and specifically in the
MYT Order dated April 13, 2022 in Petition No. 1 of 2022, the base RoE has not been
grossed up with income tax rate. CSPGCL requested the Commission to allow pass
through of income tax liabilities, if any, as and when they arise.

Commission’s View
Regulation 23 and 58 of the CSERC MYT Regulations, 2021 specify the method of
computation of RoE. The Commission has considered the opening equity for FY
2021-22 equal to equity component considered for capital cost as on COD. The
addition of equity during FY 2021-22 has been considered equal to equity portion of
capitalised works as approved in this Order. Further, return of 14% has been
considered for FY 2021-22 on the average permissible equity base during FY 2021-
22. In line with the approach adopted in previous Tariff Orders for CSPGCL, the rate
of RoE has not been grossed up with any tax rate, which is also as per the submission
of CSPGCL. The RoE approved for GP-III mine for FY 2021-22 is shown in the
Table below:
Table 3-10: Approved RoE for GP-III mines for FY 2021-22 (Rs. Crore)
Particulars Petition Approved
Opening Equity 148.63 148.63
Addition Due to Add Cap 120.24 120.24
Closing Equity 268.87 268.87
Average Equity 208.75 208.75
Rate of Return on Equity 14.00% 14.00%
Return On Equity 29.22 29.22

CSERC Tariff Order FY 2023-24 67


3.4.4 Operation and Maintenance Expenses
CSPGCL’s submission
CSPGCL referred to the observation and ruling of the Commission in the MYT Order
dated April 13, 2022 in Petition No. 1 of 2022, which is reproduced below:
“The Commission notes that CSPGCL has appointed M/s. Gare Palma
Collieries Limited as the MDO through a transparent process of competitive
bidding for undertaking the major operation and maintenance activities. The
Commission takes cognizance of the requirement of a manager and certain
statutory manpower to be deployed by mine owner to perform and discharge
the duties laid down in the Mines Act, 1952 and Coal Mines Regulation, 2017.

Since there is no CERC Order or any other reference document to project


O&M expenses for integrated mines, CSPGCL has projected O&M expenses
at 15% of MDO charges. The Commission accepts the methodology adopted
by CSPGCL for projecting O&M expenses for the Control Period, which shall
be trued up based on actuals and prudence check. However, there shall be no
sharing of gains /losses, in case the actual O&M expenses are lower than the
approved provisional O&M expenses, since the O&M expenses are being
approved on adhoc basis.”

CSPGCL submitted that it has presented the O&M expenses for FY 2021-22 as per
the Audited Accounts and the same is lower than 15% of MDO charges. However, in
accordance with the ruling of the Commission in the MYT Order dated April 13, 2022
in Petition No. 1 of 2022, CSPGCL has not claimed any gains or loss in O&M
expenses.

Commission’s View
The Commission in the MYT Order dated April 13, 2022 had approved the O&M
Expenses for GP-III mine at 15% of the MDO charges for each year of the Control
Period from FY 2022-23 to FY 2024-25 on adhoc basis, subject to true up of O&M
expenses based on actuals and prudence check. The Commission had also ruled that
there shall be no sharing gains or losses in O&M expenses in case the approved O&M
expenses are higher or lower than actual O&M expenses. For FY 2021-22, CSPGCL
has submitted that the actual O&M expenses are less than 15% of MDO charges.
Based on the actuals as per Audited Accounts for FY 2021-22, the Commission
approved the O&M expenses for FY 2021-22, as shown in the Table below:
Table 3-11: Approved O&M Expenses for GP-III mines for FY 2021-22 (Rs.
Crore)
Particulars Petition Approved
Employee Expense 7.12 7.12
A&G Expense 0.82 0.82
R&M Expense 0.05 0.05
Total 7.99 7.99

68 CSERC Tariff Order FY 2023-24


3.4.5 Interest on Working Capital
CSPGCL’s submission
CSPGCL submitted that the Interest on Working Capital has been calculated in line
with the provisions of Regulation 61 of CSERC MYT Regulations, 2021.
Accordingly working capital has been computed considering the input cost of coal
stock for 7 days production corresponding to the ATQ, stores and spares including
explosives, lubricants and fuel at 15% of O&M expenses, and O&M expenses for 15
days. As the normative O&M expenses are yet to be determined for GP-III mine, the
actual O&M expenses have been considered. CSPGCL has considered the interest rate
applicable as per CSERC MYT Regulations, 2021 for determination of interest on
working capital.

Commission’s View
Regulation 61 of the CSERC MYT Regulations, 2021 specifies as under:
“61. Interest on Working Capital:
61.1. The working capital of the integrated mine(s) of coal shall cover:
(i) Input cost of coal stock for 7 days of production corresponding to the
Annual Target Quantity for the relevant year;
(ii) Consumption of stores and spares including explosives, lubricants and fuel
@ 15% of O&M expenses, excluding mining charge of Mine Developer and
Operator and annual charges of the agency other than Mine Developer and
Operator, engaged by the generating company; and 240 CSERC Tariff Order
FY 2022-23
(iii) O&M expenses for 15 days, excluding mining charge of Mine Developer
and Operator and annual charges of the agency other than Mine Developer
and Operator, engaged by the generating company.
61.2. The rate of interest for working capital shall be determined in
accordance with Regulation 26.4 of these regulations. Truing up shall be done
as per Regulation 26.4 of these Regulations.”
Accordingly, the Interest on Working Capital for the Control Period has been
computed in accordance with Regulation 61 of the CSERC MYT Regulations, 2021.
The Commission has considered the input cost of coal stock for 7 days of production
corresponding to the ATQ for FY 2021-22. Working capital for Spares has been
worked out on the basis of 15% O&M expenses approved for FY 2021-22. Further, 15
days of O&M expenses have been considered in working capital for GP-III mines.
The interest rate of 10.90%has been considered, for computing the Interest on
Working Capital. The Interest on Working Capital allowed for FY 2021-22 is shown
in Table below:
Table 3-12: Interest on Working Capital Approved for GP-III mines for FY
2021-22 (Rs. Crore)
Particulars Petition* Approved
ATQ 3 3
Input Cost for 7 days of Stock 7.30 7.30

CSERC Tariff Order FY 2023-24 69


Particulars Petition* Approved
Spares as 15% of O&M Cost 1.20 1.20
Working capital for O&M 0.33 0.33
Total Working Capital
8.82 8.82
Requirement
Rate of Interest on WC 10.90% 10.90%
Interest on WC 0.96 0.96
*Petition values revised by CSPGCL vide additional submission dated 03/02/2023

3.4.6 Over Burden Adjustment


CSPGCL’s submission
CSPGCL submitted that as the responsibility of over burden removal is in the scope
of the MDO and at present there is no liability on CSPGCL, no Over Burden
adjustment has been considered for FY 2021-22. CSPGCL requested the Commission
to allow CSPGCL to make additional submission in this regard, as and when such a
situation arises.

Commission’s View
In accordance with the submission of CSPGCL, the Commission has not considered
any over burden adjustment for FY 2021-22.

3.4.7 GCV Adjustment


CSPGCL’s submission
CSPGCL submitted that as per the provisions of CSERC MYT Regulations, 2021, the
impact of uncontrollable factors is a pass through. As the quality of coal from a coal
seam is totally uncontrollable for a Generation Company, no adjustment in GCV of
coal is required to be made. CSPGCL further submitted that the Directorate of
Geology & Mining, Government of Chhattisgarh vide Order No. 5236 dated 7 th
October 2022 has declared GCV for different seams of the mine and there is no
declared GCV for GP-III mine. Hence, adjustments in GCV in accordance to
Regulation 66 of CSERC MYT Regulations, 2021 is not applicable. The statutory
charges are being paid in accordance to the seam-wise grade declared vide above
order and as the impact of GCV of coal is embedded in the true up of the end use
plants in comprehensive manner, no separate adjustment in GCV of coal is required.
CSPGCL also submitted that the above does not imply that there has been any
slippage of grade and any exemption is being sought against the same. Per contra,
during FY 2021-22, there were four seams available for excavation. The best coal
grade declared is G-13, while the weighted average of coal as fired is also in the same
range. Thus, there is no slippage in grade of coal. Rather, if the weighted average of
seams is considered then the actual GCV is better than the declared grade. However,
CSPGCL has not claimed any gain on this account, as GCV of coal extracted from
GP-III mines is uncontrollable for CSPGCL.

Commission’s View
Regulation 66.1 of the CSERC MYT Regulations, 2021 stipulates that in case the
weighted average GCV of coal extracted from the integrated mine(s) in a year is
70 CSERC Tariff Order FY 2023-24
higher than the declared GCV of coal for such mine(s), no GCV adjustment shall be
allowed. CSPGCL in its Petition has confirmed that actual GCV of coal is better than
the declared grade, therefore, no adjustment in GCV of coal from GP-III Coal Mine
has been carried out.

3.4.8 Non-Tariff Income (NTI) Adjustment


CSPGCL’s submission
CSPGCL submitted that the adjustment of Non-Tariff Income has been made in
accordance with Regulation 67 of the CSERC MYT Regulations, 2021.

Commission’s View
CSPGCL has considered the interest income on FDR of Rs. 110.20 Crore as Non-
Tariff Income for FY 2021-22. The Commission has accordingly considered the Non-
Tariff Income for FY 2021-22 as submitted by CSPGCL.
Table 3-13: Non-Tariff Income Approved for FY 2021-22 (Rs. Crore)
Particulars Petition Approved
Non-Tariff Income 3.34 3.34

3.4.9 Mine Closure Charges


CSPGCL’s submission
CSPGCL submitted that the liability of Mine Closure Expenses rests with the MDO
as per the provisions of Coal Mines Service Agreement (CMSA) and hence, no
expenses towards mine closure has been considered for the purpose of calculation of
Input Price of coal in True up Petition for FY 2021-22.

Commission’s View
In line with the submission of CSPGCL, the Commission has not considered Mine
Closure Expenses for GP-III mines for FY 2021-22.

3.4.10 Statutory Charges


CSPGCL’s submission
CSPGCL submitted that the Statutory charges have been considered as per various
notifications/guidelines of the Ministry of Coal. In absence of rate of coal from
integrated mine allotted through Government dispensation route, for FY 2021-22, the
base rate of coal for royalty computation, was considered at the same level as
applicable for the equivalent grade of coal from SECL mine. The directions of the
Commission and the online portal of Mineral Resource Department, Govt. of
Chhattisgarh, also allows this methodology only. However, CSPGCL requested the
Commission to allow it to make additional submissions or claim, if the authorities
decide to review the rates of taxes from retrospective effect. The Statutory charges
considered for the purpose of calculation of input price are tabulated below:

CSERC Tariff Order FY 2023-24 71


Table 3-14: Statutory Charges for GP-III mines for the Control Period as
submitted by CSPGCL
Particulars Rate Applicable on
GST 18.00% Mining Charges
Royalty 14.00% On Base Price
DMF 10.00% Royalty
NMET Fund 2.00% Royalty
Environment Cess 11.25 Rs. per Tonne
Infrastructure Development CESS 11.25 Rs. per Tonne
Forest Tax 26.23% Rs.15/Tonne
GST on Royalty, DMF and NMET 18.00%

Commission’s View
The Commission noted that in reply to data gaps, CSPGCL has submitted the copies
of all relevant Government notifications for levy of Statutory charges as claimed in
the True up Petition. The Commission has verified the same.
Regulation 52.2 of the CSERC MYT Regulations, 2021 provides that the Statutory
charges, as applicable shall be allowed in Input Price of coal.
The Commission notes the submission of CSPGCL regarding the method of payment
of Statutory charges. Any additional liability due to change in rate of taxes from
retrospective effect, if any, may be considered by the Commission in future Tariff
Petitions, subject to submission of all supporting documents and justification by
CSPGCL and after prudence check.
However, it is clarified that the compliance of the statutory provisions remain the
unfettered responsibility of the Petitioner and it is for CSPGCL to ensure that the
statutory charges are paid in accordance to the prevailing rules without delay and
demur. CSPGCL is expected to exercise due care against excess / short payment of
statutory charges. In case of any changes in the relevant provisions or applicability of
any other statutory charge, CSPGCL may pay the same and leave is granted for claim
against such payment along with due justification at the time of true up.
Based on the above, the Commission has considered the Statutory charges for GP-III
mines as under:
Table 3-15: Approved Statutory Charges for GP-III mines for FY 2021-22 (Rs.
Crore)
Particulars Petition Approved
Statutory charges 53.58 53.58

3.4.11 MDO Charges


CSPGCL’s submission
CSPGCL submitted that it has appointed Gare-Pelma III Collieries Ltd. as MDO
through open transparent competitive bidding process. The same has been adopted by

72 CSERC Tariff Order FY 2023-24


the Commission in the MYT Order dated April 13, 2022 in Petition No. 1 of 2022.
For the purpose of pre-COD period computation as well as True up for FY 2021-22,
the actual charges as per the Audited Accounts have been considered. The actual per
tonne charges are lower than the coupon rates. Thus, deductions as applied, have been
fully passed on to the beneficiaries, i.e., the Power Plants of CSPGCL.

Commission’s View
As per Regulation 53.2 of the CSERC MYT Regulations, 2025, the Run of Mine cost
will include the Mining Charge, which is the charge per tonne of coal paid by the
Generating Company to the MDO engaged by the Generating Company for mining,
wherever applicable. Since CSPGCL has appointed MDO through the process of
competitive bidding and MDO charges are discovered through bidding process, the
Commission accepts the actual MDO charges for FY 2021-22 as submitted by
CSPGCL for GP-III mines.
Table 3-16: Approved MDO Charges for GP-III mines for FY 2021-22
Particulars Petition Approved
MDO charges (Rs. Crore) 228.97 228.97
MDO charges (Rs./Tonne) 651.38 651.38

3.4.12 Sharing of Gains/Loss


CSPGCL’s submission
CSPGCL submitted that the principles of sharing of gain or loss laid down in
Regulation 12 and 13 of the CSERC MYT Regulations, 2021 are applicable in case of
the integrated coal mine also. For the operation of the integrated coal mine, the only
materialistic performance criteria are achievement of the coal production targets as set
in the approved mining plan. While the fixed reserve price and the statutory charges
are directly related to the quantity of coal produced, the financial costs - such as RoE,
interest and finance charges and depreciation are directly dependent on the average
capital cost and capital structure during the year and there is no direct relation with
the quantity of coal actually produced. Thus, in case of over / under achievement of
the production target, the per tonne cost attributable to these components tend to vary.
IOWC has also been considered as the cost component, which affects the beneficiary
in case of over / under achievement of the target. To a large extent, the O&M
expenses also follow the same path. However, as in the MYT Order dated April 13,
2022 in Petition No. 1 of 2022, the Commission has ruled that gain or loss on account
of O&M expenses shall not be considered for integrated mine, CSPGCL has not
considered any gain or loss on account of O&M expense. For calculating gain or loss
for integrated mines, CSPGCL has calculated the per tonne cost attributable to the
above cost components (ROE, interest and finance charges, depreciation and IOWC)
considering the normative ATQ, which was equal to the target set in the mining plan.
The same has been recomputed for the „actual quantity‟ achieved during the year.
When the actual production exceeds the target production, the per tonne cost of coal is
reduced benefitting the end consumer and when the actual production is lower than
the mining plan target, there is an adverse impact on the beneficiaries. As during FY
2021-22, CSPGCL exceeded the target set in the mining plan, savings have been
achieved and the gain has been shared on 50-50 basis.

CSERC Tariff Order FY 2023-24 73


Commission’s View
Regarding sharing of gains and losses, the Commission notes that there is no specific
provision mentioned in the CSERC MYT Regulations, 2021, however Regulation 70
specifies as under:
“Special Provision: Provisions of Chapters 3 and 4 of these regulations shall
not be applicable in case of integrated mine(s), except to the extent
specifically provided for or referred to in this Chapter-5.
Provided that the financial parameters required for determination of input
price of coal or lignite from integrated mine(s), if not specifically provided for
or referred to in this Chapter, shall be considered as per provisions of these
regulations as applicable to the coal or lignite based generating stations.”
The Chapter 3 deals with Financial Principles and Chapter 4 deals with the
determination of Generation Tariff. However, Chapter 2 deals with General Principles
and Regulation 12 and 13 of Chapter 2 deals with the mechanism for sharing of gains
/ losses due to controllable and un-controllable parameters. Further, the proviso of
Regulation 70 (referred above) specifies that financial parameters required for
determination of input price of coal from integrated mine, if specifically not provided
shall be considered as per provisions of the Regulations as applicable to the coal
based generating stations. Since, the sharing of gains and losses due to controllable
parameters for existing thermal power plants has been considered in the ratio of
50:50, the Commission has considered the ratio of 50:50 for sharing of gains / losses
for coal mine also.
Further, as per the ruling of the Commission in the MYT Order dated April 13, 2022
in Petition No. 1 of 2022, no sharing of gains or losses in O&M expenses for GP-III
mine is allowable. Thus, the Commission accepts the method of determination of
gains due to higher production of coal proposed by CSPGCL and has allowed the
sharing of same in the ratio 50:50.
The share of gains due to higher production of coal approved for FY 2021-22 is
shown in Table below:
Table 3-17: Sharing of Gains due to Higher Production Approved for FY 2021-
22 between GP-III Mine and CSPGCL Plants
Particulars Petition Approved
Depreciation, Interest on Loans, ROE, IoWC and
104.82 104.82
NTI (Rs. Crore)
ATQ (MMT) 3.00 3.00
AFC/ Tonne on ATQ basis (Rs. /MT) 349.38 349.38
Actual Production (Grossed up quantity of Coal
3.52 3.52
Dispatched) - MMT
AFC/ Tonne on Actual basis (Rs. /MT) 298.18 298.18
Gain/ (Loss)/ Tonne due to Excess / (less) production
18.00 18.00
(Rs. Crore)
Share of CSPGCL (Rs. Crore) 9.00 9.00

74 CSERC Tariff Order FY 2023-24


3.4.13 Fixed Reserve Price
CSPGCL’s submission
CSPGCL submitted that the Ministry of Coal, GoI, vide Notification No.
13016/9/2014 -CA III dated December 26, 2014 has fixed the Floor/ Reserve Price for
auction and allotment of coal mine/blocks as Rs. 100/MT for coal blocks allocated to
Government Companies for specified end use. Further, GST is applicable on the same
@18%. Accordingly, the Fixed Reserve Price has been considered at Rs. 118/MT for
the calculation of Input Price of coal for the Control Period.

Commission’s View
The Commission has verified the Notification of the Ministry of Coal, GoI specifying
the Fixed Reserve Price of Rs. 100/MT. The Commission allows the Fixed Reserve
Price of Rs. 118/MT for the calculation of Input Price of coal for the Control Period in
line with the Notification issued by the Ministry of Coal, GoI and considering the
applicable GST.

3.4.14 Annual Target Quantity


CSPGCL’s submission
As regard the Annual Target Quantity (ATQ), CSPGCL submitted that as per the
Regulations of the Commission, it is the quantity in accordance with the Mining Plan.
The same was relied by the Commission at the time of determination of input price in
the MYT Order dated April 13, 2022 in Petition No.1 of 2022. However, it may not
be prudent to consider the same at the time of True up. As the Regulations do not
provide any express clause or methodology for the True up, CSPGCL has considered
the actual quantity as the ATQ.
CSPGCL submitted that the „actual quantity‟ may be inferred as the excavated
quantity or the dispatch quantity from mine or the RR quantity or the net quantity
received at the plant. While the excavated quantity may be a true parameter for an
independent commercial mine, the same may not be just and proper for an integrated
mine. If at the time of True up, actual excavated quantity is considered in place of
ATQ, then it is quite possible that no coal reaches to the plant and still it may be
claimed that the integrated mine has over achieved the bench mark. It may not be
proper to consider the excavated quantity from another perspective. The input price as
per the Regulations reflects the price at the mine end including the statutory charges
as may be applicable. As the statutory charges i.e., royalty, DMF, NMET etc. are paid
only at the time of dispatch of the coal, the AEC/ton derived on the excavated
quantity may not reflect such cost components.
CSPGCL further submitted that though the dispatch quantity to a large extent meets
the criteria for consideration as actual quantity matching to the ATQ, in the cases
where multiple modes of transportation are involved, there may be difference between
the quantity dispatched from the mine and the quantity, which is finally dispatched to
the plant from any intermediate siding. Therefore, while for the purpose of integrated
mines with direct connectivity to the end use plant, the dispatch quantity is a true
reflector of actual quantity to be considered in place of the ATQ, the same may need
some correction in case of multiple transfers with intermediate yard/ sidings.

CSERC Tariff Order FY 2023-24 75


As regards the RR quantity or net quantity received at plant, CSPGCL submitted that
the input price is determined at the mine end, the FRP is paid at the time of excavation
of coal and all the other statutory charges are paid at the time the coal is dispatched
from the mine end. Therefore, consideration of RR quantity/plant quantity will lead to
under recovery of proper cost.
Based on the above, CSPGCL submitted that the quantity of coal dispatched from the
mine end commensurate to the net quantity received at the plant end is the most
proper representation of actual quantity. In other words, it applies the grossed-up
quantity from the mine end. By such methodology, true cost at the plant end can be
reflected. CSPGCL also submitted that that since the beginning of the regulatory
regime of determination of plant wise tariff, the Commission has adopted the same
principle in respect of coal from SECL. Since the coal from SECL do not involve
multiple transfers, the transit losses for only one mode were considered. In the case of
coal supply from GP-III mine, Rail Cum Road system is applicable. Hence, the net
impact of both the transit losses has to be considered.

Commission’s View
As regards the ATQ to be considered for True up, CSPGCL has submitted the pros
and cons of different quantities, i.e., extracted quantity, dispatched quantity, RR
quantity and net quantity, if considered as ATQ. The extracted quantity is least
suitable since this represents only the coal produced from mine and not the quantity
used for generation of electricity at CSPGCL plants. The dispatched quantity or RR
quantity are also not representative as they do not reflect the coal used for generation
of electricity at CSPGCL plants. The RR quantity or net quantity received at plant are
also not suitable, since the FRP is paid at the time of excavation of coal and all the
other statutory charges are paid at the time the coal is dispatched from the mine end.
Considering the above, the Commission accepts the submission of CSPGCL and
considers the ATQ as the quantity of coal dispatched from the mine end
commensurate to the net quantity received at the plant end for the purpose of True up
for input price of coal from GP-III mine for FY 2021-22.

3.4.15 Other Charges while carrying out True up of coal cost supplied from GP-III
mine
CSPGCL submitted that for the purpose of True up of coal cost for FY 2021-22 for
coal supplied from GP-III coal mine, it has considered various elements for deriving
the landed cost of the coal as discussed below:
a) Dispatch from Mine
As per the Government Policy / procedure, whenever coal is dispatched from the
mine, a transit pass is issued from the online portal maintained by Mineral
Resource Department, GoCG. The transit pass contains the vehicle number, tare
and gross weight of vehicle and the grade of coal. For the purpose of True up
Petition, CSPGCL has considered the dispatch quantity compiled from the daily
transit passes issue through the portal.
The Commission has accepted the submission of CSPGCL and has considered the
dispatch quantity compiled from the daily transit passes issued through the portal.

76 CSERC Tariff Order FY 2023-24


b) Road transportation charges
CSPGCL submitted that the actual payment of road transportation charges has
been considered from the accounts. The net quantity after accounting for the
transit losses has been considered for deriving the per tonne road transportation
charges. As there is difference between the actual quantity dispatched from the
mine and the quantity, which is dispatched from the railway siding to the plant,
the road transportation charges have been claimed only for the corresponding
quantity required for loading on the railway racks.
For the purpose of True up, the Commission has considered the road
transportation charges only corresponding to the quantity required for loading on
the railway tracks.
c) Coal dispatch from railway siding
CSPGCL submitted that the details of railway receipts (RR) are submitted along
with each FCA bill raised by CSPGCL on CSPDCL. Copies of the same are also
submitted to the Commission. For the purpose of True up Petition, the RR
quantity indicated in individual FCA bills for FY 2021-22 have been relied upon.
For True up purposes, the Commission has considered the RR quantity as
submitted in the individual FCA bills for FY 2021-22.
d) Rail transportation Charges
CSPGCL submitted that the RR details are submitted with the FCA bills. For the
purpose of true up, the quantity and charges indicated in the FCA bills are
considered.
For True up purposes, the Commission has considered the RR quantity as
submitted in the individual FCA bills for FY 2021-22.
e) Coal Sampling charges
CSPGCL submitted that as per the Regulations of the Commission, third party
sampling of coal is required. CSPGCL has appointed CIMFR, which is the most
renowned agency in coal sampling and is also a Central Government undertaking.
The rate allowed to CIMFR for carrying out the quality test is same, which is
being paid to CIMFR in case of coal supply by Coal India. However, unlike CIL
coal, in this case, the charges are borne fully by the beneficiary and the charges
are pass through.
For True up purposes, the Commission has considered the coal sampling charges
based on actual as submitted by CSPGCL.

3.4.16 Input Price of Coal


CSPGCL’s submission
CSPGCL computed the Input Price of coal from GP-III mines for FY 2021-22 as
shown in the Table below:

CSERC Tariff Order FY 2023-24 77


Table 3-18: Input Price of Coal from GP-III mines for FY 2021-22 as submitted
by CSPGCL
Particulars Unit FY 2021-22
Depreciation Rs Crore 30.05
Interest on loan Rs Crore 47.91
Return on Equity Rs Crore 29.22
Interest on Working Capital Rs Crore 0.96
O&M Charges Rs Crore 7.99
Statutory Charges Rs Crore 53.58
Sharing of gain due to
Rs Crore 9.00
Higher Production
Annual Extraction Cost Rs Crore 178.71
Actual Quantity of Coal MMT 3.52
Annual Extraction Cost Rs./ MT 508.41
MDO Charges Rs./ MT 651.38
Sub Total Rs./ MT 1159.79
Less -NTI Rs Crore 3.34
Less – NTI Rs./ MT 9.51
Add- Fixed Reserve Price Rs./ MT 118.00
Input Price Rs./ MT 1268.29

Commission’s View
Based on various components of expense and income discussed above, the approved
Input Price of coal from GP-III mines for FY 2021022 is shown in Table below.
Table 3-19: Approved Input Price of Coal from GP-III mines for FY 2021-22
(Rs. Crore)
Particulars Unit FY 2021-22
Depreciation Rs Crore 30.05
Interest on loan Rs Crore 47.91
Return on Equity Rs Crore 29.22
Interest on Working Capital Rs Crore 0.96
O&M Charges Rs Crore 7.99
Statutory Charges Rs Crore 53.58
Sharing of gain due to
Rs Crore 9.00
Higher Production
Annual Extraction Cost Rs Crore 178.71
Actual Quantity of Coal MMT 3.52
Annual Extraction Cost Rs./ MT 508.41
MDO Charges Rs./ MT 651.38
Sub Total Rs./ MT 1159.79
Less -NTI Rs Crore 3.34
Less - NTI Rs./ MT 9.51
Add- Fixed Reserve Price Rs./ MT 118.00
Input Price Rs./ MT 1268.29

78 CSERC Tariff Order FY 2023-24


Table 3-20: Breakup of Approved Input Price of Coal from GP-III mines FY 2021-22
Particulars Unit FY 2021-22
Base Price of coal Rs. /MT 997.86
Statutory Charges Rs. /MT 152.43
Fixed Reserve Price including GST Rs. /MT 118.00
Total Price/Tonne Rs. /MT 1268.29

CSERC Tariff Order FY 2023-24 79


4 TRUE-UP FOR FY 2021-22 FOR CSPGCL

4.1 Background
The Commission notified the CSERC MYT Regulations, 2015 for the third MYT
Control Period from FY 2016-17 to FY 2020-21 on September 9, 2015. Subsequently,
the Commission notified the First Amendment to CSERC MYT Regulations, 2015 on
June 16, 2017.
However, due to COVID-19, the new Regulations could not be notified and vide
Public Notice No. 03/CSERC/Tariff 2020/1227 dated November 26, 2020, the
Commission extended the prevailing MYT Regulations, 2015 till FY 2021-22 and
directions were issued to file the Tariff Petition accordingly.
Based on the direction, CSPGCL filed the Petition for determination of ARR and
Tariff for FY 2021-22 (numbered as Petition No. 09 of 2021 (T)) and an Order on the
same was issued on 2 August, 2021.
CSPGCL has now filed this Petition for true-up of FY 2021-22 for its existing thermal
generating stations, viz., HTPS, DSPM TPS, 500 MW Korba West TPP, ABVTPP,
and Hasdeo Bango Hydro Power Plant in accordance with the CSERC MYT
Regulations, 2015.
Regulation 10.4 of the CSERC MYT Regulations, 2015 specifies as under:
“10.4. The scope of the truing up shall be a comparison of the performance of the
generating company or STU/transmission licensee or distribution licensee or
SLDC with the approved forecast of Aggregate Revenue Requirement and
expected revenue from tariff and charges and shall comprise of the following:
(a) A comparison of the audited performance of the applicant for the previous
financial year(s) with the approved forecast of such previous financial
year(s), subject to the prudence check including pass-through of impact of
uncontrollable factors;
(b) Review of compliance with directives issued by the Commission from time to
time;
(c) Other relevant details, if any.”
In accordance with the above Regulation, the Commission, in the present Order, has
undertaken true-up of ARR and Revenue for FY 2021-22 on the basis of Audited
Accounts of CSPGCL.
In this Chapter, the Commission has analysed all the elements of actual expenditure
and revenue of CSPGCL for FY 2021-22 and considered the final true-up of expenses
and revenue in accordance with Regulation 10 of the CSERC MYT Regulations,
2015. The Commission has approved the sharing of gains and losses on account of
controllable factors between CSPGCL and its beneficiaries, in accordance with
Regulation 13 of the CSERC MYT Regulations, 2015.

4.2 Generation Capacity of Existing Generating Stations


The details of the existing generating stations are shown in the Table below:

80 CSERC Tariff Order FY 2023-24


Table 4-1: Generation Capacity (MW) of existing Generating Stations
Sr. No. of Units &
Particulars
No. Capacity in MW
1 Hasdeo Thermal Power Station (HTPS) 4x210 = 840 MW
2 1x500 MW Korba West Thermal Power Plant
1x500 MW=500 MW
(KWTPP)
3 Dr. Shyama Prasad Mukherjee Thermal Power
2x250=500 MW
Station (DSPM)
4 Mini Mata Hasdeo Bango Hydro Electric Project 3x40=120 MW
5 Atal Bihari Vajpayee Thermal Power Plant
2x500 = 1000 MW
(ABVTPP), Janjgir Champa

4.3 Plant Availability Factor (PAF)


CSPGCL’s submission
The actual Plant Availability Factor (PAF) for CSPGCL‟s stations for FY 2021-22 is
shown in the Table below:
Table 4-2: Actual PAF for FY 2021-22 as submitted by CSPGCL
Station FY 2021-22
HTPS 68.45%
DSPM 96.29%
KWTPP 84.93%
ABVTPP 54.67%
As regards DSPM, CSPGCL submitted that DSPM TPS has outperformed all the
performance norms.
As regards HTPS, CSPGCL submitted that during the year, there was sharp rise in
demand of coal by the Thermal Power Stations across the nation, which led to pan
India coal crisis. The reduced availability of coal was totally uncontrollable for
CSPGCL. The only option would have been import of coal but in such case the landed
cost of coal, which is less than Rs 2500/- per tonne in case of domestic coal, would
have sky rocketed to more than Rs 15000/- per tonne, implying a steep rise in energy
charges. CSPGCL also submitted that HTPS and KWTPP share a common coal
transport system and common coal yard. Further, the energy charge of the new
KWTPP is lower than the old HTPS. Hence, in the wider interest of all stakeholders,
KWTPP was allowed higher share of coal utilization.
As regards KWTPP and ABVTPS, CSPGCL submitted that coal availability affected
these Plants too. CSPGCL has considered the normative values for ABVTPS as
approved by the Commission. CSPGCL submitted that the gains / loss from
performance are proposed to be shared as per the Regulations.

Commission’s View
The Commission asked CSPGCL to provide break-up of availability in terms of
machine availability and fuel availability considering outages and fuel availability
separately for HTPS and KWTPP.

CSERC Tariff Order FY 2023-24 81


CSPGCL submitted that coal shortage during the year was a well-known phenomenon
during the year under review and HTPS was no different. The daily coal requirement
for the Plant to meet the normative generation target with normative SHR, AEC and
Calorific Value is about 19,219 Tonnes and after accounting for carpet coal, for
minimum useable coal at the very critical level (3 days), the minimum about 70000-
tonne coal may be required, however for a significant number of days the same was
not there. Under such situation, as KWTPP is a comparatively new unit and its
thermal efficiency is higher (reflected in lower normative SHR) hence, it was prudent
on the part of CSPGCL that in the larger interest of all stakeholders, more allocation
of coal was made to KWTPP.
CSPGCL also submitted that though these factors for DSPM, HTPS and ABVTPS
may be contended as uncontrollable, however, considering the view taken by the
Commission in previous Orders, no exception is pleaded, and the impact of lower
availability has been treated in line with methodology prescribed in the Regulations.
The Commission has examined the actual PAF of the generating stations for FY
2021-22 submitted by CSPGCL and verified the same from the certificate obtained
from CSLDC. The Commission has considered the actual PAF as per CSLDC‟s
certificate for FY 2021-22 for determining sharing of gains and losses.
The Commission has considered the NAPAF for all Power Stations as approved in the
Tariff Order dated 2 August, 2021.
The station-wise NAPAF and actual PAF approved by the Commission in the true-up
of FY 2021-22 is shown in the Table below:
Table 4-3: Approved Plant Availability Factor for FY 2021-22
Station NAPAF Actual PAF
HTPS 78.69% 68.45%
DSPM 85% 96.29%
KWTPP 85% 84.93%
ABVTPP 76.50% 54.67%

4.4 Auxiliary Energy Consumption


CSPGCL’s Submission
CSPGCL has submitted the actual Auxiliary Energy Consumption (AEC) for its
stations for FY 2021-22, as shown in the Table below:
Table 4-4: Auxiliary Energy Consumption for FY 2021-22 as submitted by
CSPGCL
Tariff CSPGCL’s
Station
Order Submission
HTPS 9.70% 10.04%
DSPM 9.00% 7.95%
HBPS 1.00% 0.19%
KWTPP 5.25% 5.37%
ABVTPP 5.25% 6.12%

82 CSERC Tariff Order FY 2023-24


CSPGCL submitted that during FY 2021-22, all other generating stations except
HTPS, KWTPP and ABVTPP have achieved AEC better than the specified norms.

Commission’s View
In this Order, normative AEC has been considered for truing up as approved in the
Tariff Order.
For the purpose of sharing of efficiency gains and losses, the actual AEC as submitted
by CSPGCL for FY 2021-22 has been considered. Further, the normative AEC for FY
2021-22, as shown in the Table below, has been considered for computation of
normative net generation:
Table 4-5: Approved Auxiliary Energy Consumption for FY 2021-22
Station Normative Actual
HTPS 9.70% 10.04%
DSPM 9.00% 7.95%
HBPS 1.00% 0.19%
KWTPP 5.25% 5.37%
ABVTPP 5.25% 6.12%

4.5 Gross Generation and Net Generation


CSPGCL’s Submission
CSPGCL submitted that the actual gross generation and net generation for FY 2021-
22 for its generating stations, as shown in the Table below:
Table 4-6: Actual Gross Generation and Net Generation for FY 2021-22 as
submitted by CSPGCL (MU)
Station Gross Generation Net Generation
HTPS 5044.96 4538.36
DSPM 3908.42 3597.60
HBPS 404.12 403.35
KWTPP 3734.10 3533.47
ABVTPP 4828.05 4532.54
As regards HBPS, CSPGCL submitted that the generating station not only contributes
green power but is the cheapest source of power in the State. The generating station
has achieved its operational parameters for FY 2021-22. During the year, the plant
injected much higher energy than what was envisaged. However, as in the previous
Orders, the Commission has adopted the approach that generation from the plant is
dependent on water discharge from the plant, which in turn is uncontrollable for
CSPGCL, hence, in compliance with the regulatory philosophy, no gain on account of
excess generation is being claimed.

Commission’s View
The billing mechanism has been changed from October 2014, wherein three-part ABT
billing is done based on declared capacity and corresponding scheduled energy, and
the deviations from the schedule are governed through Deviation Settlement

CSERC Tariff Order FY 2023-24 83


Mechanism (DSM). The above figures submitted by CSPGCL are the actual
generation and not the scheduled generation. For the purpose of sharing of efficiency
gains and losses, the Commission has duly verified the monthly statements submitted
by CSPGCL. The actual gross generation and net generation are based on actual
metered data and the normative gross generation and net generation have been arrived
based on normative figures approved in the Tariff Order, as shown in the Table
below:
Table 4-7: Approved Gross Generation and Net Generation for FY 2021-22
(MU)
Normative Actual
Station Gross Net Gross Net
Generation Generation Generation Generation
HTPS 5790.32 5228.66 5044.961 4538.36
DSPM 3723.00 3387.93 3908.420 3597.60
HBPS 274.00 271.26 404.123 403.35
KWTPP 3723.00 3527.54 3734.10 3533.47
ABVTPP 6701.40 6349.58 4828.045 4532.54

4.6 Gross Station Heat Rate


CSPGCL’s Submission
CSPGCL submitted the actual Gross Station Heat Rate (GSHR) for FY 2021-22 for
existing generating stations, as shown in the following Table:
Table 4-8: GSHR for FY 2021-22 (kcal/kWh)
Station FY 2021-22
HTPS 2725.59
DSPM 2409.43
KWTPP 2521.62
ABVTPP 2572.42

Commission’s View
The Commission asked CSPGCL to provide reasons for increase in GSHR as
compared to the normative parameters. CSPGCL submitted that SHR too has
relationship with the loading. Part loading (particularly below 80%) adversely affects
the turbine / boiler efficiency, which in turn reflects on SHR. As during the year, due
to coal shortage and other reasons, the availability and machine loading was lower
hence, the AEC and SHR got adversely affected. To make conditions worse, the plant
suffered from number of backing down instructions too. During the year, HTPS,
which has much lower ECR (about Rs 1.67/ unit) got 534 Backing down instructions
resulting in loss of about 41 MU generation. Thus, even when the coal shortage was
not there and machine was available, there were number of occasions when part
loading had to be resorted to. As is well known, thermal power stations are base load
stations and at times of part loading, the fluctuations in loading worsen the
performance. It may be appreciated that both conditions, i.e., coal shortage and

84 CSERC Tariff Order FY 2023-24


fluctuations in demand, were uncontrollable for CSPGCL. CSPGCL submitted that in
the petition, though the impact has been treated in line with methodology prescribed
in the MYT Regulations, 2015, however, the Commission is requested to consider the
difficulties faced due to uncontrollable factors and allow relief as may be deemed fit.
After due verification, the actual GSHR as submitted by CSPGCL for FY 2021-22 has
been considered for the computation of actual Fuel Cost and the normative GSHR as
approved in Tariff Order dated August 11, 2021 has been considered for computation
of normative Fuel Cost. GSHR for thermal power stations as approved by the
Commission for FY 2021-22 are shown in the Table below:
Table 4-9: Approved GSHR for FY 2021-22 (kcal/kWh)
Station Normative Actual
HTPS 2,650.00 2725.59
DSPM 2,500.00 2409.43
KWTPP 2,375.00 2521.62
ABVTPP 2,378.42 2572.42

4.7 Secondary Fuel Oil Consumption


CSPGCL’s Submission
CSPGCL has submitted the actual Secondary Fuel Oil Consumption (SFOC) for FY
2021-22 as shown in the Table below:
Table 4-10: SFOC submitted by CSPGCL for FY 2021-22 (ml/kWh)
Station Tariff Order Actual
HTPS 0.90 0.87
DSPM 0.50 0.09
KWTPP 0.50 0.28
ABVTPP 0.50 0.50

Commission’s View
The Commission observes that all generating stations have achieved the norms for
SFOC. For the purpose of sharing of efficiency gains/losses, actual SFOC has been
considered vis-a-vis normative SFOC for computation of normative fuel cost, as
shown in the Table below:
Table 4-11: Approved SFOC for FY 2021-22 (ml/kWh)
Station Normative Actual
HTPS 0.90 0.87
DSPM 0.50 0.09
KWTPP 0.50 0.28
ABVTPP 0.50 0.50

CSERC Tariff Order FY 2023-24 85


4.8 Transit Loss
CSPGCL’s Submission
CSPGCL has submitted the actual transit loss as shown in the following Table:
Table 4-12: Transit loss as submitted by CSPGCL for FY 2021-22
Station FY 2021-22
HTPS 0.19%
DSPM 0.198%
KWTPP 0.19%
ABVTPP 0.9138%

CSPGCL submitted that during FY 2021-22, due to coal crisis at national level and
difficulty faced by Coal India in supplying additional coal required for DSPM TPS, in
the larger interest of all the stakeholders, part of coal required for DSPM was supplied
from GP III mine. The applicable norm of transit loss for the plant is to consider
weighted average of normative transit losses for SECL coal and the GP III coal. For
the DSPM TPS, the normative transit loss for SECL coal is 0.20%, but for coal
transported from GP III mine, normative transit loss has been taken as 0.9984%. The
weighted average normative transit loss for the plant comes out to 0.288% for DSPM.
Regarding transit loss for AVBTPS, CSPGCL submitted that during the year, the
bridge linkage from Coal India came to an end and as per the Government Policy, no
extension was granted. Further, during the year, to meet the coal requirement,
substantial quantity of coal supply was ensured from GP III mine. Therefore, the
applicable norm for the plant is to consider weighted average of normative transit
losses for SECL coal and the GP III coal.
As far as coal from GP III mine is concerned, coal from integrated mine has been
dealt for the first time in MYT Regulations, 2021 and the last proviso of Regulation
43.6 specifically states:

“In case of integrated mines, the transit and handling loss shall be decided on
case to case basis subject to prudence check”.
CSPGCL further submitted that the Transit loss depends upon the mode of transport.
In case of dedicated mode (i.e., pit head), the normative transit loss is allowed as 0.2%
and in case of public mode transport (i.e., non pit head), the allowable normative loss
is 0.80%. In case of an integrated mine, the coal transfer may take place through
multiple modes. It may be LDCC, or MGR or Indian Railway or Trucks or a
combination of such modes. Hence, the Commission, took a stand for deciding such
cases on case-to-case basis.
The coal transport from GP III mine, involves dual transport in RCR (Rail Cum Road)
mode. First, coal is transported from mine to railway siding through trucks (which
may be considered as dedicated mode) and then from railway siding, transportation
occurs through Indian Railways (which is public transport). As per settled principle,
for the first phase, the applicable normative transit loss is 0.20% and for the next
phase (railway siding to plant) the applicable normative loss is 0.80%. Combining the
two the resultant net normative transit loss for GP III coal transported through
Robertson/ Gharghoda siding, stands at 0.9984%.

86 CSERC Tariff Order FY 2023-24


For ABVTPS, the normative transit loss for SECL coal is 0.80%. Accordingly, taking
into account the share of SECL coal and GP III coal, the weighted average normative
transit loss for the plant comes out to 0.9763%.

Commission’s View
The actual transit loss for FY 2021-22 has been considered as submitted by CSPGCL
for the purpose of sharing of efficiency gains and losses, while the normative transit
loss for FY 2021-22 has been considered as approved in the Tariff Order, for
computation of normative fuel cost.
Regarding coal transportation from GP III mine, the Commission notes that it
involves dual transport in RCR (Rail Cum Road) mode. First, coal is transported from
mine to railway siding through trucks (considered as dedicated mode) and then from
railway siding transportation occurs through Indian railways (which is public
transport). As per CSERC MYT Regulations, 2015, the applicable normative transit
loss is 0.20% for dedicated mode and 0.80% for public transport. Combining the two,
the resultant net normative transit loss for GP III coal transported through Robertson/
Gharghoda siding, stands at 0.9984%. Since, coal was also supplied to DSPM during
the year, appropriate adjustment in the normative transit loss has been considered.
Table 4-13: Approved Transit loss for FY 2021-22
Station Normative Actual
HTPS 0.20% 0.19%
DSPM 0.286% 0.198%
KWTPP 0.20% 0.19%
ABVTPP 0.9763% 0.9138%

4.9 Calorific Value and Price of Fuel


CSPGCL’s Submission
CSPGCL submitted that Regulation 41.6 of the CSERC MYT Regulations, 2015
specifies that the energy charge shall cover the fuel cost (primary fuel as well as
secondary fuel). Fuel cost has been considered as per settled methodology adopted in
all previous Orders. CSPGCL has submitted the plant-wise landed rate of coal and oil
for thermal power plants and coal cost, oil cost and energy charge rate computation.
CSPGCL also submitted that the coal supply by SECL for the 1x500 MW KWTPP
plant was from the same source and same mode, which is available for HTPS old
plant (4 x 210 MW). As per well settled methodology, with common coal stock, the
base data of coal receipt has been taken same as considered for HTPS old plant. The
consumption has been booked as per actual.
Similarly, the landed price of the Fuel oil has been computed considering common
procurement for HTPS and KWTPP. However, fuel consumption as per actual has
been considered separately for these plants.
For ABVTPS, coal was received from SECL as well as the integrated mine at GP –III.
For coal received from GP–III mine, as no Regulations were in place at that time,
hence, as per the Commission‟s directions, the ECR and FCA were computed in
accordance with the notified price of equivalent grade of coal from SECL. Later on,
the Regulations for the current Control Period were notified which contain a Chapter

CSERC Tariff Order FY 2023-24 87


for determination of cost of coal from captive coal mines. It also provides that for coal
mines which achieved COD before April 1, 2022, the cost of coal for such prior
period shall be computed in accordance with the Regulations and the excess / under
recovery shall be dealt at the time of true up. The cost of coal from the integrated
mine at GP III has been computed accordingly in the Petition.
CSPGCL submitted the actual Calorific Value (CV) and price of fuels for FY 2021-
22, as shown in the following Table:
Table 4-14: Actual Calorific Value and Price of fuels for FY 2021-22
Coal Secondary Fuel
Station Calorific
Actual Price of Calorific Value Actual Price of
Value
Fuel (Rs. /MT) (kcal/kL) Fuel (Rs. /kL)
(kcal/kg)
HTPS 3,446.03 1860.64 10,000.00 63,049.63
DSPM 3,355.74 2079.60 10,000.00 89,068.21
KWTPP 3,423.61 1860.64 10,000.00 63,049.63
ABVTPP 3,470.00 2270.61 10,000.00 66,308.06

Commission’s View
Common facility is used for transportation of coal for HTPS and KWTPP. In the
present Tariff Petitions, CSPGCL has submitted that coal is supplied by SECL to
HTPS and KWTPP from the same source and hence, the landed price of coal has been
considered on integrated basis and the same rate has been used for computation of
fuel cost for both the plants. As per the settled practice, the Commission in True-up of
FY 2021-22 accordingly considers the submission of CSPGCL for landed price of
coal for HTPS and KWTPP.
For the coal supply made from GP-III Coal Mine, the Commission has considered the
input price as determined in this Order for FY 2021-22.
The Commission has considered the actual fuel prices as submitted by CSPGCL for
computation of actual fuel cost and actual fuel price at normative transit loss for
computation of normative fuel cost for FY 2021-22. The calorific value of fuel and
price of fuel considered by the Commission for computation of actual and normative
fuel cost for FY 2021-22 are shown in the Table below:
Table 4-15: Approved Calorific Value and Price of fuels for FY 2021-22
Coal Secondary Fuel
Actual Price Actual Price Actual
Station Calorific Calorific
at Normative at Actual Price of
Value Value
Transit Loss Transit Loss Fuel
(kcal/kg) (kcal/kL)
(Rs. /MT) (Rs. /MT) (Rs. /kL)
HTPS 3,446.03 1,860.83 1,860.64 10,000.00 63,049.63
DSPM 3,355.74 2,081.43 2,079.60 10,000.00 89,068.21
KWTPP 3,423.61 1,860.83 1,860.64 10,000.00 63,049.63
ABVTPP 3,470.00 2,272.04 2,270.61 10,000.00 66,308.06

88 CSERC Tariff Order FY 2023-24


4.10 Fuel Cost
CSPGCL’s Submission
The Table below shows the fuel cost claimed by CSPGCL in the True-up of
FY 2021-22:
Table 4-16: Actual Fuel Cost for FY 2021-22 (Rs. Crore)
Station Normative Actual
HTPS 858.63 767.65
DSPM 592.73 586.38
KWTPP 491.32 517.75
ABVTPP 1,063.64 827.18

Commission’s View
Based on the approved performance parameters, calorific values of fuels and fuel
prices, the normative and actual fuel cost has been computed for FY 2021-22 as
shown in the Table below:
Table 4-17: Approved Fuel Cost for FY 2021-22 (Rs. Crore)
Station Normative Actual
HTPS 858.63 767.65
DSPM 592.73 586.38
KWTPP 491.32 517.75
ABVTPP 1,063.64 827.18

4.11 Annual Fixed Charges for CSPGCL


Regulation 35 of the CSERC MYT Regulations, 2015 specifies the components of
Annual Fixed Charges (AFC) for CSPGCL as under:
(a) Depreciation;
(b) Return on Equity;
(c) Interest and Finance Charges;
(d) Interest on Working Capital;
(e) Operation and Maintenance Expenses;
Less:
(f) Non-Tariff Income
In addition to the above, the Commission has approved the Contribution to Pension
Fund as a part of AFC in the Tariff Order for FY 2021-22.

4.12 Capital Cost and Additional Capitalisation


CSPGCL’s Submission
CSPGCL submitted that the opening GFA and capital structure (Debt / Equity) for FY
2021-22, have been taken as per the closing values approved by the Commission in
the final True-up of FY 2020-21. Additions have been considered as per accounts /

CSERC Tariff Order FY 2023-24 89


Fixed Asset Register (FAR) after mapping with approved Capital Investment Plans
(CIPs).
As the Regulatory principles and practices slightly differ from financial accounting
principles and practices, there are some deviations from accounts as mentioned below:
 The Commission directed for erection and commissioning of new 220 kV
interconnecting line between DSPM TPS and the KTPS vide Order dated 15
November, 2017. The work related to erection of two number feeder bays at
DSPM TPS was allocated to CSPGCL. For proper execution and better
coordination in the line and bay work, CSPGCL assigned the work to
CSPTCL. An advance of Rs. 6.04 Crore was issued to CSPTCL on 31 August,
2019. During the year under consideration, on 25 October, 2021 at 18:33
hours, the feeders were successfully charged and the power flow is taking
place since then. As per the well settled Regulatory principle, an asset
qualifies for capitalization as soon as it is “put to use”. Thus, the expenditure
incurred on erection and commissioning of the bays qualified for capitalization
during FY 2021-22. However as this was a unique work involving the two
Companies, during the capitalization process on SAP, some procedural issues
crept in which led to non-capitalization of the expenditure in the books of
accounts for FY 2021-22. In the Accounts, the capitalization will appear in FY
2022-23. However as per the settled principle in the Tariff Order dated 30
May, 2020 on the Petition No. 02 of 2020(T), in such cases, for the regulatory
treatment, the capitalization has to be considered in the year in which the
qualifying criteria has been satisfied. Accordingly, CSPGCL has considered
capitalization of Rs. 6.04 Crore, i.e., the advance paid against the work.
CSPGCL submitted that in FY 2022-23, no additional capitalization against
the said work shall be claimed except for the difference between the
capitalization, which may appear in the audited accounts and the capitalization
considered in the instant petition.
 During the year under consideration, it was earlier planned that the Complete
Overhaul (COH) of Unit No. 2 at HTPS may be undertaken in the month of
March 2022. Accordingly, user divisions issued indents for withdrawal of
required items from the stores. However, due to system constraints and
logistical issues, the work could be undertaken in the first quarter of FY 2022-
23. Thus, these expenses would qualify for regulatory claim in the true up for
FY 2022-23. Accordingly, CSPGCL has not claimed such expense incurred on
condenser tubes, to the tune of approximately Rs. 3.22 Crore though the same
appear in the financial accounts.
 Following the same principle and for the same reason, CSPGCL has also not
claimed repair and maintenance expense of Rs 2.80 Crore and Rs. 2.76 Crore
for economizer coil element (lower and upper bank). As the work got
completed in first quarter of FY 2022-23, leave is humbly craved for claiming
these expenses during true up of FY 2022-23.
Further, in compliance with the directive of the Commission and in line with
consideration adopted by the Commission in the previous True-up Orders, the
Petitioner has attempted to segregate the capital expenses considered in the books of
accounts on best effort basis.

90 CSERC Tariff Order FY 2023-24


Commission’s View
The station-wise additional capitalisation submitted by CSPGCL and additional
capitalisation incurred have been duly scrutinised. After due prudence check, the
Commission has considered the additional capitalisation for HTPS, DSPM, Hasdeo
Bango, KWTPP and ABVTPP.
With regard to capitalisation of new 220 kV interconnecting line between DSPM TPS
and KTPS, as per settled Regulatory principle, an asset qualifies for capitalisation as
soon as it is “put to use”, hence, the Commission has considered the expenditure
incurred on erection and commissioning of the bays for capitalisation during FY
2021-22. CSPGCL shall not claim such expenses during FY 2022-23.
Since, work pertaining to COH of Unit No. 2 of HTPS and repair and maintenance
expenses for economiser coil element got completed in FY 2022-23, the Commission
grants liberty to claim such expenses during the truing up of FY 2022-23 subject to
prudence check.
The Commission accordingly approves the additional capitalisation claimed in True-
up of FY 2021-22 for all the power stations as shown in the Table below:
Table 4-18: Approved Additional Capitalisation in true up for FY 2021-22
(Rs. Crore)
Station Tariff Order Petition Approved
HTPS 114.20 89.97 89.97
DSPM 13.86 11.66 11.66
HBPS 3.07 - -
KWTPP 80.54 84.19 84.19
ABVTPP 155.74 15.56 15.56
Total 367.41 201.39 201.39

4.13 Means of Finance for Additional Capitalisation


CSPGCL’s submission
CSPGCL has considered the capital structure in line with the provisions of
Regulations 17.1 and 17.3 of the CSERC MYT Regulations, 2015 and the settled
methodology in the previous Orders. In cases of higher than normative equity, the
normative debt:equity (D:E) ratio has been considered. However, for additional
capitalisation of the project cost at KWTPP and ABVTPS, the opening D:E ratio has
been considered at 82.86:17.14 for KWTPP and at 87.56:12.44 for ABVTPP. For new
schemes, normative capital structure has been considered.

Commission's View
The Commission has considered the normative debt equity ratio of 70:30 in
accordance with provisions of CSERC MYT Regulations, 2015 for all generating
stations except for ABVTPP and KWTPP. The excess equity in capitalisation has
been considered as normative loan. As regards additional capitalisation of the Project
Cost for KWTPP, the Commission has considered the debt equity ratio as submitted
by CSPGCL. As regards ABVTPP, since the additional capitalisation is within the
approved project cost, the equity in additional capitalisation of the Project Cost is
considered in the same ratio of 87.56:12.44 as approved in Order dated July 07, 2018.
CSERC Tariff Order FY 2023-24 91
The approved means of finance for additional capitalisation for FY 2021-22 is shown
in the Table below:
Table 4-19: Approved Means of Finance for existing stations for FY 2021-22
(Rs. Crore)
CSPGCL Petition Approved
Station
Equity Debt Total Equity Debt Total
HTPS 26.99 62.98 89.97 26.99 62.98 89.97
DSPM 3.50 8.16 11.66 3.50 8.16 11.66
HBPS 0 0 0.00 0 0 0.00
KWTPP 15.07 69.13 84.19 15.07 69.13 84.19
ABVTPP 2.56 13.00 15.56 2.56 13.00 15.56
Total 48.11 153.27 201.39 48.11 153.27 201.39

4.14 Depreciation
CSPGCL’s submission
CSPGCL submitted that Depreciation for DSPM has been computed by applying the
weighted average depreciation rate on the average regulatory Gross Fixed Assets
(GFA). The weighted average depreciation rate has been computed by applying
category-wise scheduled rates specified in Regulation 24.4 of CSERC MYT
Regulations, 2015 on average GFA.
For KWTPP and ABVTPS, in the Tariff Order for FY 2021-22, the depreciation rate
was determined in accordance with the last proviso of Regulation 24.4, hence, as per
settled philosophy, in the true up, the principle relied in the Tariff Order has been
adopted and depreciation rate has been worked out accordingly.
For HTPS, CSPGCL has computed the average depreciation rate on assets added after
1 April, 2010 as per the settled methodology adopted by the Commission in the
previous Orders.
The depreciation for Hasdeo Bango Hydel plant has been computed in accordance
with the first proviso of Regulation 24.4 and in line with the methodology adopted in
the MYT Order, by spreading the balance depreciable value over the balance useful
life.
The summary of the depreciation claimed by CSPGCL for FY 2021-22 is shown in
the Table below:
Table 4-20: Depreciation for FY 2021-22 as submitted by CSPGCL (Rs. Crore)
Hasdeo
Particulars HTPS DSPM TPS KWTPP ABVTPP
Bango
Opening GFA 620.18 2,374.10 111.22 3611.80 8771.85
Additional Capitalization 89.97 11.66 0.00 84.19 15.56
Closing GFA 710.15 2,385.76 111.22 3695.99 8787.41
Average GFA 665.17 2,379.93 111.22 3,653.90 8,779.63
Average Rate of Depreciation 5.31% 5.47% 6.09% 5.94%
Balance Depreciation to be
24.95
recovered

92 CSERC Tariff Order FY 2023-24


Hasdeo
Particulars HTPS DSPM TPS KWTPP ABVTPP
Bango
Balance Useful Life 9.00
Depreciation 35.31 130.16 2.77 222.49 521.53
Accumulated Depreciation
233.39 1,659.41 77.92 1,585.38 2697.08
till 31.03.2022

Commission's View
For HTPS, the Commission in its previous Orders, has already allowed full recovery
of the balance depreciable value of old capital cost of the assets. Hence, no balance
depreciation value for original capital cost has been considered. For the additional
capitalisation after 2010, the depreciation on average GFA and depreciation rate based
on scheduled depreciation rates of 5.32% for FY 2021-22 have been considered.
As regards KWTPP and ABVTPP, the Commission in accordance with the provision
specified in Regulation 24.4 of the CSERC MYT Regulations, 2015 has accepted the
submission of CSPGCL and has considered the revised average depreciation rates of
6.09% and 5.94%, respectively, as submitted by CSPGCL for FY 2021-22.
For DSPM, the Commission has computed depreciation based on scheduled rates
specified in the CSERC MYT Regulations, 2015. Depreciation has been computed by
applying the weighted average depreciation rate of 5.47% on average GFA.
For Hasdeo Bango, the depreciation has been considered over the balance useful life
of the plant, as per the methodology adopted in past Orders.
In view of the above, the Commission approves the Depreciation for FY 2021-22 after
final true-up, as shown in the Table below:
Table 4-21: Depreciation approved for CSPGCL for FY 2021-22 (Rs. Crore)
DSPM Hasdeo
Particulars HTPS KWTPP ABVTPP
TPS Bango
Opening GFA 620.18 2,374.10 111.22 3611.80 8771.85
Additional
89.97 11.66 0.00 84.19 15.56
Capitalization
Closing GFA 710.15 2,385.76 111.22 3695.99 8787.41
Average GFA 665.17 2,379.93 111.22 3,653.90 8,779.63
Average Rate of
5.31% 5.47% 6.09% 5.94%
Depreciation
Balance Depreciation to
- - 24.95 - -
be recovered
Balance Useful Life - - 9.00 - -
Depreciation 35.31 130.16 2.77 222.49 521.53
Accumulated
Depreciation till 233.39 1,659.41 77.92 1,585.38 2697.08
31.03.2022

CSERC Tariff Order FY 2023-24 93


4.15 Return on Equity
CSPGCL’s submission
CSPGCL has computed RoE as per Regulation 22 of the CSERC MYT Regulations,
2015 for FY 2021-22. CSPGCL submitted that as regards the Income Tax, CSPGCL
has religiously followed the principle adopted by the Commission in the previous
Orders and accordingly claim is limited to actual Income Tax. Further, CSPGCL
craved leave for submission of income tax liability, if any, which may arise after
scrutiny by the Income Tax Department in future. CSPGCL prayed to approve the
same in line with the prior Orders.
CSPGCL submitted the station-wise RoE for FY 2021-22 as shown in the Table
below:
Table 4-22: Return on Equity for FY 2021-22 as submitted by CSPGCL (Rs.
Crore)
Hasdeo
Particulars HTPS DSPM KWTPP ABVTPP
Bango
Permissible Equity in
442.34 707.01 38.11 619.33 1091.72
Opening GFA
Equity addition during the
26.99 3.50 0.00 15.07 2.56
year
Permissible Equity in
469.33 710.51 38.11 634.40 1094.28
Closing GFA
Rate of return on Equity 15.50% 15.50% 15.50% 15.50% 15.50%
Return on Equity 70.65 109.86 5.91 97.16 169.41

Commission’s View
Regulation 22 of the MYT Regulations, 2015 specifies as under:
“22. RETURN ON EQUITY
22.1 Generation and Transmission: Return on Equity shall be computed in
rupee terms on the equity base determined in accordance with Regulation 17.
Return on equity shall be computed on pre-tax basis at the base rate of
maximum 15.5 % to be grossed up as per Regulation 22.3 of these Regulations.

22.3 The rate of return on equity for each year of the control period shall be
computed by grossing up the base rate with the prevailing MAT rate of the
base year: Provided that return on equity with respect to the actual tax rate
applicable to the generating company or the transmission licensee or
distribution licensee, as the case may be, in line with the provisions of the
relevant Finance Acts of the respective year during the Control Period shall be
trued up separately for each year of the Control Period. In case, no tax is
payable during the financial year, the tax rate for the purpose of truing up
shall be taken as nil.…”

94 CSERC Tariff Order FY 2023-24


For existing stations, the closing equity approved in true-up for FY 2020-21 has been
considered as the opening equity for FY 2021-22. The addition of equity has been
considered equivalent to equity amount approved towards additional capitalisation.
RoE has been computed as per Regulation 22 of the MYT Regulations, 2015.
In line with the approach adopted in previous Tariff Orders, the grossing up of base
rate of RoE with the applicable tax rate has not been considered. The base rate of RoE
of 15.50% has been considered as specified in the MYT Regulations, 2015. RoE
approved for FY 2021-22 is shown in the table below:
Table 4-23: Approved Return on Equity for FY 2021-22 (Rs. Crore)
Hasdeo
Particulars HTPS DSPM KWTPP ABVTPP
Bango
Opening Equity 442.34 707.01 38.11 619.33 1091.72
Equity addition during
26.99 3.50 0.00 15.07 2.56
the year
Closing Equity 469.33 710.51 38.11 634.40 1094.28
Rate of return on Equity 15.50% 15.50% 15.50% 15.50% 15.50%
Return on Equity 70.65 109.86 5.91 97.16 169.41

Further, CSPGCL has claimed Income Tax of Rs. 9.20 Crore for FY 2021-22. Since,
the Commission has not considered pre-tax RoE rate for computation of RoE for FY
2021-22, the Commission has allowed the actual Income Tax paid during FY 2021-
22, as reflecting in the Audited Accounts of FY 2021-22, in line with the approach
adopted in previous Orders. The Commission accordingly approves the Income Tax
of Rs. 9.20 Crore for FY 2021-22 for CSPGCL. The Commission has considered the
amount of Income Tax approved for FY 2021-22 in the Table for computation of final
Revenue Gap for FY 2021-22.
The Commission asked CSPGCL whether any Income Tax refund of previous years,
received by CSPGCL in FY 2021-22 and how the same has been adjusted in the
Income Tax claim of FY 2021-22. CSPGCL submitted that in none of the previous
years, for CSPGCL, the RoE was grossed up by the tax rate. The tax was always
allowed by the Commission on actual basis. During the year, refund of Rs. 59.89
Crore has been received for AY 2020-21. From combined reading of the income tax
refund order and the True up Order for FY 2019-20, it can be noted that though actual
pre-paid tax of Rs. 130.57 Crore was paid, actual income tax was computed as Rs.
70.68 Crore and refund of Rs. 59.89 Crore was claimed. In the true up, only the
computed tax of Rs. 70.68 Crore was claimed and allowed by the Commission. No
claim was made / allowed for the refund claim of Rs. 59.89 Crore. The said refund
claim materialized during FY 21-22. As explained above, as the above refund was
never considered as pass through by the Commission hence, no treatment of such
refund from the income tax being claimed this year is applicable.
The Commission has accepted the submission of CSPGCL regarding receipt of
income tax refund since at the time of True up for FY 2019-20, actual income tax
computed as Rs. 70.68 Crore was allowed and not entire income tax amount of Rs.
130.57 Crore paid. Therefore, no treatment of such refund from the income tax has
been made in the true up for FY 2021-22.

CSERC Tariff Order FY 2023-24 95


4.16 Interest and Finance Charges
CSPGCL’s submission
CSPGCL submitted that Interest and Finance charges have been computed for FY
2021-22 as per Regulation 23 of the CSERC MYT Regulations, 2015. There is no
change in the principle or methodology from previous Orders. As per the procedure
adopted by the Commission in the previous Orders, the repayment of regulatory loan
during the year is deemed to be equal to the depreciation allowed for the year.
The interest rate prevailing on 1st April of the year has been taken from quarterly
statements issued by PFC. Further, timely payment rebate, which does not appear in
the quarterly statement issued by PFC, but is allowed separately, has also been passed.
Finance charges have been considered as per actuals. Savings from refinancing have
been computed as per the settled methodology.
The Interest and Finance charges submitted by CSPGCL for FY 2021-22 are shown in
the Table below:
Table 4-24: Interest & Finance Charges as submitted by CGPGCL for
FY 2021-22 (Rs. Crore)
Particulars HTPS DSPM KWTPP ABVTPP
Opening Normative loan 171.89 137.84 1,629.59 5,504.60
Repayment during the period 35.31 130.16 222.49 521.53
Debt Addition during the year 62.98 8.16 69.13 13.00
Closing Net Normative Loan 199.56 15.84 1,476.22 4,996.08
Weighted Average Interest Rate (%) 11.43% 10.25% 10.15% 10.15%
Interest Expense for the Period 21.22 7.88 157.62 532.94
Sharing of net savings for re-
- 0.15 3.62 12.24
financing
Financing and Other Charges 0.06 0.04 0.04 0.09
Total Interest Expenses 21.28 8.07 161.28 545.28

Commission’s View
The Commission has computed Interest and Finance charges for FY 2021-22 as per
Regulation 23 of CSERC MYT Regulations, 2015.
For existing stations, the closing net normative loan balance approved after True-up
for FY 2020-21 has been considered as opening net normative loan balance for FY
2021-22. The debt addition has been considered as equal to debt amount approved in
this Order towards additional capitalisation for FY 2021-22. The deprecation has been
considered as normative repayment during the year.
The actual weighted average interest rate as on April 1, 2021 have been considered as
per accounts and documentary evidences as submitted by CSPGCL. Accordingly, the
station-wise weighted average rate of interest has been considered for FY 2021-22.
As per Regulation 23.8 of the CSERC MYT Regulations, 2015, the savings in re-
financing shall be shared between the beneficiaries, i.e., CSPDCL, and CSPGCL in
the ratio of 2:1. The Commission, in the past Tariff Orders, while undertaking true-up
96 CSERC Tariff Order FY 2023-24
for FY 2020-21, has adopted a methodology for sharing the savings of re-financing.
The same methodology has been continued in the present Order. Accordingly, net
savings have been computed separately and allowed in addition to Interest and finance
charges. Further, the Commission notes that CSPGCL has not claimed any additional
cost for re-financing of loan, hence, the same has not been considered.
In view of the above, the Interest and Finance charges approved by the Commission
for FY 2021-22 are shown in the Tables below:
Table 4-25: Interest & Finance Charges approved for FY 2021-22 (Rs. Crore)
Particulars HTPS DSPM KWTPP ABVTPP
Opening Normative loan 171.89 137.84 1,629.59 5,504.60
Repayment during the period 35.31 130.16 222.49 521.53
Debt Addition during the year 62.98 8.16 69.13 13.00
Closing Net Normative Loan 199.56 15.84 1,476.22 4,996.08
Weighted Average Interest Rate (%) 11.43% 10.25% 10.15% 10.15%
Interest Expense for the Period 21.22 7.88 157.62 532.94
Sharing of net savings for re-
- 0.15 3.62 12.24
financing
Financing and Other Charges 0.06 0.04 0.04 0.09
Total Interest Expenses 21.28 8.07 161.28 545.28

4.17 Normative Operation and Maintenance (O&M) expenses


CSPGCL’s Submission
CSPGCL submitted the O&M Expenses (excluding water charges and SLDC charges)
for existing thermal and hydel power plants in accordance with Regulation 38.5 of the
CSERC MYT Regulations, 2015.
CSPGCL further submitted that as per the methodology adopted in earlier Orders,
O&M Expenses in the support functions such as Head Office, CAU, etc., are allocated
among the thermal power plants and Hasdeo Bango HEP, based on their
installed/effective capacities.
CSPGCL also submitted that it has computed the normative O&M expenses in the
similar manner as approved in the previous Orders.
However, at KTPS, after retirement of the plant, during the year under consideration,
along-with the decommissioning activities, the O&M of switchyard and hydrogen
plant remained in service. During the year, the switchyard was transferred to CSPTCL
at notional cost of Rs 1/- but for smooth transition CSPGCL continued O&M support
till 31 March, 2022. As per settled principle, the employee cost, being pass through,
has been clubbed with CAU cost. The R&M and A&G incurred for switchyard and
hydrogen plant and also for decommissioning activities have been submitted as
separate line item. However, in the Petition, no claim has been included against the
same. In line with the principle approved by the Commission in the previous Order,
CSPGCL craved leave to submit the R&M and A&G cost incurred during the year at
the time of settlement of salvage value and income from sale of scrap, which is
expected during FY 2022-23.

CSERC Tariff Order FY 2023-24 97


For the purpose of normalization of O&M expenses for FY 2021-22, CSPGCL has
considered weighted average WPI-CPI inflation as shown in the following Table:
Table 4-26: CPI and WPI Index considered by CSPGCL
Particulars FY 2021-22
WPI Variation 13.00%
CPI variation 5.13%
Average (60:40) 8.28%
CSPGCL further submitted that the normative O&M Expenses for KWTPP and
ABVTPS, whose COD was later than April 1, 2010, have been computed as per
Regulation 38.5.1.1 of the CSERC MYT Regulations, 2015, normalizing the same
with actual weighted average rate of inflation.
CSPGCL submitted that it has not considered the productivity incentive, donations
and CSR expenses as part of employee expenses for regulatory purposes, as per the
methodology settled in the previous Orders. Further, in light of the first amendment to
the Regulations and as per the methodology adopted in previous true ups, separate
computation of impact of wage revision has not been considered.
In the Accounts, the leave encashment expenses have been settled against the
provision made in the previous year. In the previous orders, the Commission has
taken a view that for the true-up purpose, instead of provisions, only actual
expenses/income shall be considered. Accordingly, actual leave encashment has been
considered as part of employee cost within O&M Expenses.
CSPGCL further submitted that as per Regulations, the MYT Order has not
considered the contribution to the pension trust as part of O&M expenses. For the
purpose of this petition, CSPGCL has also followed the same.
Further, as per the methodology adopted in earlier Orders, the cost incurred on coal
transport has been reduced from the O&M Expenses and added to the fuel cost.
The O&M Expenses submitted by CSPGCL for FY 2021-22 is shown in the Table
below:
Table 4-27: O&M Expenses for FY 2021-22 submitted by CSPGCL (Rs. Crore)
Station Petition
HTPS 308.12
DSPM 171.06
HBPS 8.07
KWTPP 115.21
ABVTPP 252.12
Total 854.58

Commission’s View
As regards O&M Expenses, Regulation 38.5 of the MYT Regulations, 2015 specifies
as under:
“38.5 Operation and Maintenance expenses
………
Employee Cost
98 CSERC Tariff Order FY 2023-24
c) The employee cost, excluding pension fund contribution, impact of pay
revision arrears and any other expense of non-recurring nature, for the
base year i.e. FY 2016-17, shall be derived on the basis of the normalized
average of the actual employee expenses excluding pension fund
contribution, impact of pay revision arrears and any other expense of non-
recurring nature, available in the accounts for the previous five (5) years
immediately preceding the base year FY 2016-17, subject to prudence
check by the Commission.
d) The normalization shall be done by applying last five year average
increase in Consumer Price Index (CPI) on year to year basis. The average
of normalized net present value for FY 2011-12 to FY 2015-16, shall then
be used to project base year value for FY 2016-17. The base year value so
arrived, shall be escalated by the above inflation rate to estimate the
employee expense (excluding impact of pension fund contribution and pay
revision, if any) for each year of the Control Period.
At the time of true up, the employee costs shall be considered after taking
into account the actual increase in CPI during the year instead of
projected inflation for that period.
Provided further that impact of pay revision (including arrears) and
pension fund contribution shall be allowed on actual during the true-up as
per accounts, subject to prudence check and any other factor considered
appropriate by the Commission.
A&G Expenses and R&M Expenses
e) The administrative and general expenses (excluding water charges) and
repair and maintenance expenses, for the base year i.e. FY 2016-17, shall
be derived on the basis of the normalized average of the actual
administrative and general expenses (excluding water charges) and
repair and maintenance expenses, respectively available in the accounts
for the previous five (5) years immediately preceding the base year FY
2016-17, subject to prudence check by the Commission. Any expense of
non-recurring nature shall be excluded while determining normalized
average for the previous five (5) years.
f) The normalization shall be done by applying last five year average
increase in Wholesale Price Index (WPI) on year to year basis. The
average of normalized net present value for FY 2011-12 to FY 2015-16,
shall then be used to project base year value for FY 2016-17. The base
year value so arrived, shall be escalated by the above inflation rate to
estimate the administrative and general expense and repair and
maintenance expenses for each year of the Control Period.
At the time of true up, the administrative and general expenses and repair and
maintenance expenses shall be considered after taking into account the actual
inflation instead of projected inflation for that period.
Provided that water charges shall be pass-through in tariff on reimbursement
basis.” (emphasis added)

CSERC Tariff Order FY 2023-24 99


The Commission had determined the O&M Expenses for FY 2021-22 in accordance
with the above Regulation. The above Regulation specifies that at the time of truing
up, the O&M Expenses shall be considered after taking into account the actual
inflation instead of projected inflation for that period.
Accordingly, the Commission has computed the normative O&M expenses for FY
2021-22 by applying the actual inflation on base O&M expenses for FY 2020-21 as
approved in previous True-up Order, by considering the actual CPI and WPI for FY
2021-22. For FY 2021-22, the Commission has considered escalation factor of 5.13%
for employee expenses and 13% for R&M expenses and A&G Expenses. Further, as
regards KWTPP and ABVTPP, the normative O&M expenses have been determined
in accordance with the norms specified in the CSERC MYT Regulations, 2015, with
escalation factor considered as 8.28% for FY 2021-22.
CSPGCL submitted that it has not considered the productivity incentive, donations
and CSR expenses as part of employee expenses for regulatory purposes, as per the
methodology settled in the previous Orders.
Accordingly, the normative O&M Expenses computed for FY 2021-22 are as shown
in the Table below:
Table 4-28: Approved Normative O&M Expenses for FY 2021-22 (Rs. Crore)
Tariff Revised Normative
Particulars
Order Expenses
HTPS 361.03 374.74
DSPM 179.95 190.72
Hasdeo Bango 15.62 16.06
KWTPP 108.74 113.58
ABVTPP 217.47 227.16
As regards the actual O&M Expenses, the Commission sought reconciliation of actual
O&M Expenses submitted in the Petition vis-à-vis O&M Expenses reported in
audited accounts. The Commission has considered the actual O&M Expenses as
submitted by CSPGCL after due prudence check.
The Commission has undertaken sharing of gains and losses as per CSERC MYT
Regulations, 2015, between normative expenses and actual expenses as per Audited
Accounts.
As regards the sharing of gains and losses, the following provision has been inserted
in Regulation 13.1 by the First Amendment to the MYT Regulations, 2015 on June
16, 2017:
“Provided further that employee cost shall not be factored in for sharing of
gains or losses on account of operations and maintenance expenses…”
Accordingly, the Commission approves the actual Employee Expenses as per audited
Accounts for FY 2021-22, and Employee cost is not considered for sharing of gains or
losses. The sharing of gains and losses has been undertaken in subsequent section of
this Chapter.
In this Order, the Commission approves the O&M expenses based on audited
accounts for FY 2021-22. The normative and actual O&M Expenses approved by the
Commission is shown in the following Table:

100 CSERC Tariff Order FY 2023-24


Table 4-29: Approved O&M Expenses for FY 2021-22 (Rs. Crore)
Particulars Actual Normative
HTPS 308.12 374.74
DSPM 171.06 190.72
Hasdeo Bango 8.07 16.06
KWTPP 115.21 113.58
ABVTPP 252.12 227.16

4.18 Pension and Gratuity Contribution


CSPGCL’s Submission
CSPGCL submitted that the Commission in the MYT Order approved Pension and
Gratuity (P&G) Fund Trust Contribution by CSPGCL as Rs. 233.23 Crore. Plant-wise
allocation considered in the Order has been maintained. CSPGCL submitted that
actual contribution to the Trust has been in conformity to the Order.
CSPGCL further submitted the plant-wise allocation considered as shown in the Table
below:
Table 4-30: Pension and Gratuity Contribution for FY 2021-22 as submitted by
CSPGCL (Rs. Crore)
Tariff CSPGCL’s
Station
Order Petition
HTPS 104.49 104.49
DSPM 38.77 38.77
HBPS 3.30 3.30
KWTPP 23.21 23.21
ABVTPP 63.46 63.46
Total 233.23 233.23

Commission’s View
The P&G contribution of Rs. 233.23 Crore has been approved for CSPGCL for FY
2021-22 in the Tariff Order dated August 2, 2021. The Commission has considered
the same in the Truing-up for FY 2021-22.

4.19 Interest on Working Capital


CSPGCL’s Submission
CSPGCL submitted that it has calculated the normative Interest on Working Capital
(IoWC) as per Regulation 25 of CSERC MYT Regulations, 2015. Normative cost of
coal/oil has been taken as per Regulation 25.1(a) (i)/(ii), O&M cost as per sub-clause
(iii), and cost of maintenance spares has been taken as per sub-clause (iv). The
Receivables have been computed as per Regulation 25.2 equivalent to one (1) month
of actual revenue billed.
As per Regulation 25.4, IoWC has been calculated at the rate equal to the applicable
Base Rate of State Bank of India as on 1st April plus 350 basis points for the year, i.e.,
10.90%.

CSERC Tariff Order FY 2023-24 101


CSPGCL submitted the interest on working capital as shown in the Table below:
Table 4-31: IoWC for FY 2021-22 as submitted by CSPGCL (Rs. Crore)
Tariff CSPGCL’s
Particulars
Order Petition
HTPS 27.71 28.47
DSPM 19.16 21.35
HBPS 0.50 1.02
KWTPP 16.94 18.11
ABVTPP 40.45 37.75
Total 104.75 106.70

Commission’s View
The Commission has computed the IoWC for FY 2021-22 as per Regulation 25 of the
MYT Regulations, 2015. The rate of interest has been considered as 10.90% for FY
2021-22 as per the provisions of MYT Regulations, 2015. The revised normative
O&M expenses have been considered for computation of Working Capital
requirement. The actual revenue billed, excluding the Gap/Surplus of the previous
year/s, has been considered as receivables for computation of working capital
requirement. Further, in line with the approach adopted in the past Orders, DSPM has
been considered as a pithead station, and one-month cost of coal has been considered.
Accordingly, the IoWC approved by the Commission after truing up for FY 2021-22
is shown in the Table below:
Table 4-32: Approved IoWC for CSPGCL for FY 2021-22 (Rs. Crore)
Particulars Tariff Order Approved
HTPS 27.71 28.47
DSPM 19.16 21.35
HB 0.50 1.02
KWTPP 16.94 18.11
ABVTPP 40.45 37.75
Total 104.75 106.70

4.20 Non-Tariff Income


CSPGCL’s submission
CSPGCL submitted the Non-Tariff Income as per Regulation 38.6 of the CSERC
MYT Regulations, 2015 for FY 2021-22 for its existing Stations. For computation
purpose, plant-specific income has been booked to respective plants and income
appearing against HO and CAU has been allocated to thermal plants on the basis of
installed/effective capacity. Delayed Payment Surcharge has not been taken into
account while determining the Non-Tariff Income for FY 2021-22 as per well-settled
principle in previous Orders.
As per settled methodology, provisions for income as well as expenses are not
considered for the purpose of true-up. However, there are specific exclusions from
Non-Tariff Income, which are detailed below.

102 CSERC Tariff Order FY 2023-24


As regards interest on Fixed Deposit Receipt (FDR), except for the interest on FDR
maintained for Coal Blocks, all other interest income appearing in the Accounts has
been considered. The interest attributable to FDR value of Rs. 110.20 Crore has been
considered as NTI for GP III mine (along with other income appearing in the Gare
Palma Accounts) and the interest attributable to FDR of about Rs. 132.048 Crore for
Gidhmuri Pathuria Coal block has been reduced from expenses on the Gidhmuri
Pathuria mine.
In-line with the previous Order, no income from sale of assets at KTPS has been
considered, as the same is accounted for recovery of salvage value, stores and the cost
of decommissioning. The cost of decommissioning includes R&M and A&G cost
after the retirement of the plant. Further, as per the regulatory principle, 10% of GFA
is recovered through the salvage value. The balance value of stores and inventories
has also to be charged to the cost of scrap. Thus, even after accounting for the revenue
of Rs. 30 Crore in FY 2020-21 and Rs. 46.05 Crore in FY 2021-22, there is balance
residual value of more Rs. 61 Crore, which still qualifies for recovery through tariff.
However, as further receipts are due in FY 2022-23, as settled in the previous Order,
no claim has been made in the Petition on account of such residual recovery.
CSPGCL craved leave for submission of detailed settlement of revenue from sale of
scrap and recovery of salvage value of plant/ balance stores / cost of decommissioning
etc., as allowed in the previous Order.
The Non-Tariff Income submitted by CSPGCL for FY 2021-22 is shown in the Table
below:
Table 4-33: Non-Tariff Income for FY 2021-22 as submitted by CSPGCL (Rs.
Crore)
Tariff CSPGCL’s
Station
Order Petition
HTPS 7.15 9.42
DSPM 3.71 5.47
HBPS 0.03 0.02
KWTPP 3.03 5.19
ABVTPP 6.38 11.05
Total 20.30 31.15

*Note: CSPGCL vide its additional submission dated February 3, 2023 submitted that
in absence of any express accounting head of interest on refund of Income Tax, in the
trail balance, the same got subsumed in the account head “Interest on other loans and
advances” therefore CSPGCL rectified the error and requested not to consider as
part of NTI and submitted the revised NTI amount as Rs. 31.15 Crore.

Commission’s View
The Commission approves the station-wise Non-Tariff Income based on actuals as per
the Audited Accounts and considering CSPGCL‟s submissions, for the purpose of
truing up for FY 2021-22, as shown in the Table below:

CSERC Tariff Order FY 2023-24 103


Table 4-34: Approved Non-Tariff Income in True-up for FY 2021-22 (Rs. Crore)
Particulars Tariff Order Approved
HTPS 7.15 9.42
DSPM 3.71 5.47
KWTPP 0.03 0.02
HB 3.03 5.19
ABVTPP 6.38 11.05
Total 20.30 31.15

4.21 Ash Utilization Expenses


CSPGCL’s Submission
CSPGCL submitted that the Ministry of Environment and Forests (MoEF) amended
the Environment (Protection) Act, 1986 vide notification dated January 25, 2016.
Since, the notification was issued after the notification of CSERC MYT Regulations,
2015, CSPGCL did not get an opportunity to consider the implications of the said
amendment and the O&M expenses were computed as per CSERC MYT Regulations,
2015 and the actual cost implication kept on piling up.
Regulation 11.1 lists the uncontrollable factors and the entry at 11.1 (b) is “Change in
law”. Further, Regulation 12 provides that any gain/loss on account of uncontrollable
item shall be pass through in ARR. During the previous year, CSPGCL submitted the
difficulty due to diversion of O&M funds for Ash Utilization and prayed for allowing
detailed submission in the matter.
The Commission vide its Order dated August 2, 2021 in Petition No. 09 of 2021 has
taken cognizance of the matter concerning the allowance of additional O&M expenses
under “Change in Law” for utilization of fly ash. Further, vide Order dated April 13,
2022 in Petition No. 1 of 2022, the Commission has allowed such expenses as pass
through.
For FY 2021-22, the Ash Utilization expenses have been reduced from the O&M
expenses and equal amount has been claimed under the separate head. Thus, the total
expenses remain same.

Commission’s View
The Commission vide its Order dated August 2, 2021 in Petition No. 09 of 2021 had
taken cognizance of the matter concerning the allowance of additional O&M expenses
under “Change in Law” for utilization of fly ash. Further, vide Order dated April 13,
2022 in Petition No. 1 of 2022, the Commission has allowed such expenses as pass
through.
The Commission, in line with the previous Orders, has approved the Ash Utilization
expenses under the separate head in ARR. The Ash Utilization Expense approved by
the Commission are shown as below:
Table 4-35: Ash Utilization Expenses as approved (Rs. Crore)
Year HTPS DSPM ABVTPS KWTPP
CSPGCL 6.56 1.42 19.14 4.51
Approved 6.56 1.42 19.14 4.51

104 CSERC Tariff Order FY 2023-24


4.22 Statutory Charges
CSPGCL’s Submission
CSPGCL submitted that as per the CSERC MYT Regulations, 2015, it has claimed
the statutory and other charges such as water charges, SLDC charges, Start-up power
charges, etc., on reimbursement basis. CSPGCL has recovered the same accordingly.
In view of the above, on these counts, no deficit/surplus is claimed in true up.
CSPGCL submitted that Rs. 131.80 Crore as Water Charges, Rs. 5.94 Crore as SLDC
Charges and Rs. 5.18 Crore as Start-up power charges have been claimed for FY
2021-22, totalling to Rs. 142.92 Crore for FY 2021-22.
Further, CSPGCL submitted that as per Regulation 82 of CSERC MYT Regulations,
2015, the petition filing fee and publication expenses are directly chargeable and
hence, the expenses incurred towards petition filing fee and publication expenses have
been reduced from O&M expenses and are claimed separately.

Commission’s View
For the purpose of the truing up for FY 2021-22, the Commission has considered
Statutory Charges based on audited accounts for FY 2021-22.

4.23 Aggregate Revenue Requirement for CSPGCL for FY 2021-22


The Summary of ARR for HTPS, DSPM, HBPS, ABVTPP, and KWTPP for FY
2021-22 is shown in the following Table:

CSERC Tariff Order FY 2023-24 105


Table 4-36: Approved ARR for CSPGCL’s Generating Stations for FY 2021-22 (Rs. Crore)
HTPS DSPM KWTPP ABVTPP Hasdeo Bango
Particulars Tariff Tariff Tariff Tariff Tariff
Petition Approved Petition Approved Petition Approved Petition Approved Petition Approved
Order Order Order Order Order
Depreciation 37.73 35.31 35.31 130.52 130.16 130.16 233.99 222.49 222.49 532.78 521.53 521.53 2.96 2.77 2.77
Interest & Finance
24.29 21.28 21.28 8.86 8.07 8.07 170.52 161.28 161.28 571.84 545.28 545.28 0.00 0.00
Charges
Return on Equity 72.71 70.65 70.65 110.06 109.86 109.86 97.92 97.16 97.16 170.07 169.41 169.41 5.92 5.91 5.91
O&M Expenses 361.03 308.12 308.12 179.95 171.06 171.06 108.74 115.21 115.21 217.47 252.12 252.12 15.62 8.07 8.07
Interest on
27.71 28.47 28.47 19.16 21.35 21.35 16.94 18.11 18.11 40.45 37.75 37.75 0.50 1.02 1.02
Working Capital
Less: Non-Tariff
7.15 9.42 9.42 3.71 5.47 5.47 3.03 5.19 5.19 6.38 11.05 11.05 0.03 0.02 0.02
Income
Total Annual
516.45 454.42 454.42 444.90 435.03 435.03 625.12 609.07 609.07 1,526.18 1,515.04 1,515.04 24.94 17.75 17.75
Capacity Charge
Cost of Coal 759.20 740.08 740.08 517.34 583.38 583.38 438.47 511.17 511.17 872.06 811.10 811.10 0.00
Cost of Oil 25.99 27.57 27.57 9.52 3.01 3.01 9.29 6.58 6.58 16.60 16.08 16.08 0.00
Total Energy
784.93 767.65 767.65 526.86 586.38 586.38 447.92 517.75 517.75 888.67 827.18 827.18 0.00 0.00 0.00
Charges
Pension and
Gratuity 104.49 104.49 104.49 38.77 38.77 38.77 23.21 23.21 23.21 63.46 63.46 63.46 3.31 3.30 3.30
Contribution
Ash Utilization
0.00 6.56 6.56 1.42 1.42 4.51 4.51 0.00 19.14 19.14 0.00 0.00 0.00
Expenses
Aggregate
Revenue 1,405.86 1,333.12 1,333.12 1,010.59 1,061.60 1,061.60 1,096.25 1,154.54 1,154.54 2,478.31 2,424.82 2,424.82 28.24 21.05 21.05
Requirement

106 CSERC Tariff Order FY 2023-24


4.24 Sharing of Gains and Losses
Regulation 11 of the CSERC MYT Regulations, 2015 specifies as under:
“11. CONTROLLABLE AND UN-CONTROLLABLE FACTORS
11.1 For the purpose of these Regulations, the term “uncontrollable
factors” shall comprise of the following factors, but not limited to,
which were beyond the control of the applicant, and could not be
mitigated by the applicant:
(a) Force Majeure events;
(b) Change in law
... ...
11.2 For the purpose of these Regulations, the term “Controllable
factors” shall comprise of the following:
...
(b) Generation Performance parameters like SHR, Auxiliary
consumption, etc;

(f) Variation in Wires Availability and Supply Availability”

Further, Regulation 12 of the CSERC MYT Regulations, 2015 specifies as under:


“12. MECHANISM FOR PASS THROUGH OF GAINS OR LOSSES
ON ACCOUNT OF UNCONTROLLABLE FACTORS
The aggregate net gains / losses to the generating company or
STU/transmission licensee or distribution licensee on account of
uncontrollable items (as per the tariff order) over such period shall be
passed on to beneficiaries/consumers through the next ARR or as may
be specified in the Order of the Commission passed under these
Regulations.”

Regulation 13 of the CSERC MYT Regulations, 2015 specifies as under:


“13. MECHANISM FOR SHARING OF GAINS OR LOSSES ON
ACCOUNT OF CONTROLLABLE FACTORS
The mechanism for sharing of aggregate net gain on account of over
achievement in reference to the target set in tariff order for efficiency
linked controllable items other than energy losses computed in
accordance to Regulation 7l shall be passed on to the beneficiary /
consumer(s) and retained by the generating company or the licensee or
SLDC, as the case may be, in the ratio of 50:50 or as may be specified
in the Order of the Commission passed under these Regulations.
Provided that the mechanism for sharing of aggregate net gain on
account of over achievement in reference to the target set in tariff

CSERC Tariff Order FY 2022-23 107


order for energy losses computed in accordance to Regulation 71 shall
be passed on to the consumer(s) and retained by the licensee, as the
case may be, in the ratio of 2: 1 or as may be specified in the Order of
the Commission passed under these Regulations.
13.2. The mechanism for sharing of aggregate net loss on account of
under achievement in reference to the target set in tariff order for
efficiency linked controllable items shall be passed on to the
beneficiary / consumer(s) and retained by the generating company or
the licensee, as the case may be, in the ratio of 50:50 or as may be
specified in the Order of the Commission passed under these
Regulations."

CSPGCL’s Submission
CSPGCL submitted that Regulation 13 specifies the method for sharing of gains and
losses. The well settled principles, as adopted by the Commission in previous Orders,
has been adopted. In accordance with Regulations and as per settled methodology in
previous Orders, the pension fund contribution, being old unfunded statutory liability,
has been segregated from AFC and considered as a separate line item. Further, as per
amendment to the CSERC MYT Regulations, 2015 dated June 16, 2017, Employee
cost has been excluded from the O&M cost for the purpose of sharing of
Gains/Losses. Also, in line with previous Order, impact of DSM charges has been
shared in 50:50 ratio. CSPGCL submitted the sharing of loss of Rs. 149.53 Crore for
FY 2021-22.

Commission’s View
The sharing of gains and losses on account of controllable factors has been computed
in accordance with the methodology adopted by the Commission in previous Orders.
The contribution to P&G Fund and Employee Cost has been excluded from the
calculations, and gains/losses have been shared in the ratio of 50:50 in accordance
with the CSERC MYT Regulations, 2015. Further, sharing of gains and losses of
DSM Charges has also been considered.
The sharing of gains and losses after final True-up for FY 2021-22 is as shown in the
Table below:
Table 4-37: Approved Sharing of Gains and Losses for final True-up for FY
2021-22 for CSPGCL’s Generating Stations
Hasdeo
Particulars Units HTPS DSPM KWTPP ABVTPS
Bango
Fixed Charges @
NAPAF
Installed capacity MW 840 500 500 1000 120
NAPAF as per MYT
% 78.69% 85.00% 85.00% 76.50% -
Regulations
Actual PAF achieved
% 68.45% 96.29% 84.93% 54.67% -
(billed)
Normative Net
MU 5228.66 3387.93 3527.54 6349.58 400.08
Generation

108 CSERC Tariff Order FY 2022-23


Hasdeo
Particulars Units HTPS DSPM KWTPP ABVTPS
Bango
Actual Net generation MU 4538.36 3597.60 3533.47 4532.54 403.35
Net generation for Fuel
MU 4538.36 3597.60 3533.47 4532.54 403.35
Cost recovery
Fixed Cost (norm-wise)
Depreciation Rs Crore 35.31 130.16 222.49 521.53 2.77
Interest on Loan and
Rs Crore 21.28 8.07 161.28 545.28 0.00
Finance charges
Return on Equity Rs Crore 70.65 109.86 97.16 169.41 5.91
Interest on Working
Rs Crore 28.47 21.35 18.11 37.75 1.02
Capital
O & M Expenses Rs Crore 374.74 190.72 113.58 227.16 16.06
Less - Non Tariff Income Rs Crore 9.42 5.47 5.19 11.05 0.02
Fixed Cost allowed on
Rs Crore 521.05 454.68 607.44 1490.08 25.75
Normative Basis
Fixed cost expenditure
Rs Crore 146.30 263.96 493.85 1262.92 9.68
excluding O&M
Normative Fixed Cost
Rs
(Cr. Rs/% of PAF) 1.86 3.11 5.81 16.51 0.02
Crore/%PAF
excluding O&M
Prorata Fixed cost
allowable from Actual Rs Crore 127.27 299.02 493.45 902.53 9.76
PAF
Fixed cost gain from
Rs Crore -19.04 35.06 -0.41 -360.39 0.08
normative cost
Total gain / loss Rs Crore -344.69
R&M + A&G expenses
Normative R&M + A&G
Rs Crore 134.39 105.17 64.74 129.48 4.38
Cost allowed
Normative R&M + A&G Rs
1.71 1.24 0.76 1.69 0.01
Cost (Cr. Rs/% of PAF) Crore/%PAF
Prorata R&M + A&G
cost allowable from Rs Crore 116.90 119.13 64.69 92.53 4.42
actual PAF
Actual R&M + A&G
Rs Crore 111.99 70.52 66.30 119.93 2.82
expenditure
Difference of recovery
Rs Crore 4.90 48.62 -1.61 -27.40 1.60
and expenditure
Total gain / loss 26.12
Secondary Fuel Cost
Normative SFC Rs Crore 32.86 16.58 11.74 22.22
Normative SF Cost
derived from Norm Net Rs/kwh 0.06 0.05 0.03 0.03
Gen
Secondary fuel cost Rs Crore 28.52 17.61 11.76 15.86

CSERC Tariff Order FY 2022-23 109


Hasdeo
Particulars Units HTPS DSPM KWTPP ABVTPS
Bango
recovery from actual
generation
Actual SFC incurred Rs Crore 27.57 3.01 6.58 16.08
Savings due to
performance Rs Crore 0.94 14.60 5.18 -0.22
improvement
Total Impact of
Savings/Excess Rs Crore 20.51
Expenditure due to SFC
Coal Cost (primary
fuel)
Normative Coal Cost Rs Crore 825.7690 576.15 479.582 1041.42
Normative ECR (Coal) Rs/kwh 1.58 1.70 1.36 1.64
Normative fuel cost on
Rs Crore 716.75 611.81 480.39 743.40
actual sent out
Actual fuel cost Rs Crore 740.08 583.38 511.17 811.10
Coal Cost
Rs Crore -23.33 28.43 -30.78 -67.70
Surplus/(deficit)
Total Impact of
Savings/Excess Rs Crore -93.38
Expenditure due to Coal
Total plant wise impact
Rs Crore -36.52 126.71 -27.62 -455.70 1.68
of gain/ loss
Total Impact of
Savings/Excess Rs Crore -391.45
Expenditure
Plant-wise Impact of
Rs Crore 27.95 23.46 17.45 23.52 0.00
DSM Charges
Total Impact of DSM
Rs Crore 92.38
Charges
Net total Impact
Savings/Excess Rs Crore -299.07
Expenditure
Net applicable
Gain/(Loss) to CSPGCL Rs Crore -149.53
on 50:50 basis

From the above table, it is seen that CSPGCL has incurred loss of Rs. 299.07 Crore in
FY 2021-22. As per the provisions of the Regulations, 50% of this loss has to be
retained by CSPGCL and remaining 50% will be passed on to the consumers of the
State. Accordingly, the Commission approves the loss of Rs. 149.53 Crore for FY
2021-22, after undertaking the sharing of gains and losses.

110 CSERC Tariff Order FY 2022-23


4.25 Revenue Gap/(Surplus) for CSPGCL for FY 2021-22
Commission’s view
The Commission has considered the revenue from sale of power based on the Audited
Accounts submitted by CSPGCL for FY 2021-22.
The Water Charges, SLDC Charges and Start Up Power Charges have been
considered separately for FY 2021-22. The revenue from DSM Charges has been
apportioned for respective Generating Station.
The Commission has considered the Income Tax of Rs. 9.20 Crore approved in earlier
section of this Order separately in the Revenue Gap/(Surplus) Table for FY 2021-22.
In view of the above, the Revenue Gap/(Surplus) for CSPGCL for FY 2021-22 after
final truing up has been approved as shown in the Table below:
Table 4-38: Revenue Gap/(Surplus) after True-up for FY 2021-22 for CSPGCL
(Rs. Crore)

Particulars Petition Approved


ARR for HTPS 1,333.12 1,333.12
ARR for DSPM TPS 1,061.60 1,061.60
ARR for KWTPP 1,154.54 1,154.54
ARR for ABVTPP 2,424.82 2,424.82
ARR for Hasdeo Bango 21.05 21.05
Total ARR for Generating Stations of
5,995.12 5,995.12
CSPGCL
Sharing of Gain/(Losses) -149.53 -149.53
Petition Filing Fee & Advertising expenses 0.47174 0.47174
Impact of previous year‟s Revenue Gap 324.03 324.03
Water, SLDC Charges and Start up power for
142.92 142.92
recovery
Cost on account of Change in law 40.83 40.83
Income Tax for Current Year 9.20 9.20
Total ARR 6,363.04 6,363.04
Revenue from sale of power for HTPS 1,301.73 1,301.73
Revenue from sale of power for DSPM TPS 1,100.49 1,100.49
Revenue from sale of power for KWTPP 1,144.64 1,144.64
Revenue from sale of power for ABVTPP 1,860.69 1,860.69
Revenue from sale of power for Hasdeo Bango 40.59 40.59
Total Revenue from Sale of Power for
5,448.14 5,448.14
CSPGCL
Water, SLDC charges & start up power for
142.92 142.92
recovery
Recovery Impact previous year Revenue Gap 324.03 324.03
Total Recovery and Revenue 5,915.09 5,915.09
Standalone ARR Gap/(Surplus)for the year 447.94 447.94

CSERC Tariff Order FY 2022-23 111


The Commission approves Standalone Revenue Gap of Rs. 447.94 Crore after
Truing-up of FY 2021-22.
The Commission has considered carrying cost on the Revenue Gap arrived after final
Truing-up of FY 2021-22. The Commission has considered the interest rates as SBI
Base Rate plus 350 basis points for FY 2021-22 as specified in the Regulations:
Table 4-39: Revenue Gap after True-up for FY 2021-22 for CSPGCL along with
carrying cost (Rs. Crore)

Particulars FY 2021-22 FY 2022-23 FY 2023-24


Opening Gap/(Surplus) for the year - 472.36 514.87
Gap/(Surplus) for the year 447.94 -
Closing Gap/(Surplus) 447.94 472.36 -
Interest Rate (%) 10.90% 9.00% 9.00%
Carrying Interest/Cost for the year 24.41 42.51 23.17
Total Closing Gap/(Surplus) 472.36 514.87 538.04

Accordingly, the Revenue Gap including carrying cost, which is required to be


factored in the revenue requirement of CSPDCL for FY 2023-24 works out to
Rs. 538.04 Crore.
The Commission, hence, approves cumulative Revenue Gap of Rs. 538.04 Crore
up to FY 2023-24 for CSPGCL. CSPGCL is allowed to recover the same in 12
equal monthly instalments from April 2023 from CSPDCL. This Revenue Gap
has been adjusted in ARR of CSPDCL for FY 2023-24 as discussed in
subsequent Chapter.

112 CSERC Tariff Order FY 2022-23


5 TRUE-UP OF ARR FOR FY 2021-22 FOR CSPTCL
5.1 Background
The Commission notified the CSERC MYT Regulations, 2015 for the third MYT
Control Period from FY 2016-17 to FY 2020-21 on September 9, 2015. Subsequently,
the Commission notified the First Amendment to CSERC MYT Regulations, 2015 on
June 16, 2017. The Commission vide public notice CSERC letter 03/CSERC/Tariff
2020/1228 dated November 26, 2020 has notified the extension of CSERC MYT
Regulations, 2015 for the next year, i.e., 2021-22. The Commission has determined
the ARR and Tariff for FY 2021-22 on August 02, 2021 and the final true up of ARR
for FY 2021-22 had been carried out by comparing actual performance with the
values as approved in the Order dated August 02, 2021.
Based on the audited accounts of FY 2021-22, CSPTCL has submitted the Petition for
final true-up of ARR for FY 2021-22.
Regulation 10.4 of the CSERC MYT Regulations, 2015 specifies as under:
“10.4. The scope of the truing up shall be a comparison of the performance of
the generating company or STU/transmission licensee or distribution licensee or
SLDC with the approved forecast of Aggregate Revenue Requirement and
expected revenue from tariff and charges and shall comprise of the following:
(d) A comparison of the audited performance of the applicant for the previous
financial year(s) with the approved forecast of such previous financial
year(s), subject to the prudence check including pass-through of impact of
uncontrollable factors;
(e) Review of compliance with directives issued by the Commission from time to
time;
(f) Other relevant details, if any.”
In accordance with the above Regulation, in the present order, final true-up of ARR
for FY 2021-22 is undertaken based on audited accounts as submitted by CSPTCL.
In this Chapter, the Commission has analysed all the elements to identify actual
expenditure and revenue of CSPTCL for FY 2021-22 and undertaken the final true-up
of expenses and revenue in accordance with Regulation 10 of the CSERC MYT
Regulations, 2015. The Commission has approved the sharing of gains and losses on
account of controllable factors between CSPTCL and its beneficiaries, in accordance
with Regulation 13 of the CSERC MYT Regulations, 2015.

5.2 Transmission System of CSPTCL


The physical status of the transmission system of CSPTCL as on March 31, 2021 and
March 31, 2022, as submitted by CSPTCL, is shown in the Table below:

CSERC Tariff Order FY 2022-23 113


Table-5-1: Physical status of transmission system of CSPTCL as on March 31, 2022
Particulars Units As on March 31, 2021 As on March 31, 2022
A. EHV Transmission Lines
400 kV ckt. km. 1918 1918
220 kV ckt. km. 4032 4032
132 kV ckt. km. 7192 7496
B. EHV Substations
400 kV No. 4 4
220 kV No. 25 26
132 kV No. 94 95
C. Transformation Capacity of EHV Substations
400/220 kV MVA 2835
220/132 kV MVA 9460
132/33 kV MVA 9290

5.3 Transmission Losses


CSPTCL’s Submission
CSPTCL submitted that based on the actual reading of the energy meters installed at
the various points of the State‟s periphery, the actual transmission loss for FY 2021-
22 is 3.02%. The computation of the transmission losses submitted by CSPTCL is
shown in the Table below:
Table 5-2: Transmission Losses for FY 2021-22 as submitted by CSPTCL (MU)
Sr.
Particulars FY 2021-22
No.
1 State Generation Ex-Bus at 132 kV and above 16611.25
2a Import from CTU Grid at CG Periphery at 132 kV and above 19455.17
2b Export to CTU Grid at CG Periphery at 132 kV and above 6954.59
2 Net Drawal from CTU Grid at State Periphery at 132 kV and 12500.58
above
3 IPPs/CPP Injection in CSPTCL System at 132 kV and above 1255.32
4 Total Injection at State Grid of STU (MU) (1+2+3) 30367.15
5 EHV Sales from Sub Station 3514.00
6 Net Output to DISCOM 25929.46
7 Sum of import of data of transformers and import of data of 5.29
Generating station feeder‟s import
8 Total Output from CSPTCL System (5+6+7) 29448.75
9 Transmission Loss (4-8) 918.39
10 Transmission Loss (%) (9/4*100) 3.02%

114 CSERC Tariff Order FY 2022-23


Commission’s View
In the Tariff Order for FY 2021-22 dated August 2, 2021, the transmission losses
were approved as 3.00% for FY 2021-22. The details of source-wise actual injection
of energy, actual EHV sales and joint meter readings have been examined.
The Commission approves the transmission loss of 3.02% for FY 2021-22 as
submitted by CSPTCL.

5.4 Operations and Maintenance (O&M) Expenses


CSPTCL’s Submission
Employee Expenses
CSPTCL submitted that based on the audited accounts, the gross employee expense
excluding SLDC expense is Rs. 188.32 Crore for FY 2021-22, as shown in the
following Table:
Table 5-3: Gross Employee Expenses for FY 2021-22 as submitted by CSPTCL
(Rs. Crore.)

Sr. FY 2021-22
Particulars
No. Actual
Gross Employee Expenses (CSPTCL + SLDC) excluding 197.78
1
Terminal Benefits
2 Less: SLDC Employee Expenses 9.46
3 CSPTCL Gross Employee Expenses 188.32

The capitalisation of employee expenses has been considered as Rs. 11.00 Crore for
FY 2021-22. CSPTCL requested the Commission to approve actual net employee
expenses (net of capitalization) of Rs. 177.32 Crore for FY 2021-22.
CSPTCL submitted the details of sanctioned employee strength, current employee
strength, and vacant positions for different class of employees, as on March 31, 2022.
The total sanctioned strength of different class of employees exclusive of SLDC is
3,075 out of which 1,479 are currently working and balance 1596 are envisaged to be
filled in the coming financial years, as shown in the Table below:
Table 5-4: Employee strength of CSPTCL as on 31st March 2022

Sr.
Particulars Sanctioned Working Vacant
No.
CSPTCL
1 Class I 159 144 15
2 Class II 241 187 54
3 Class III 1,533 740 793
4 Class IV 1,142 408 734
5 Total 3,075 1,479 1,596

CSERC Tariff Order FY 2022-23 115


Sr.
Particulars Sanctioned Working Vacant
No.
SLDC
1 Class I 20 19 1
2 Class II 24 12 12
3 Class III 24 14 10
4 Class IV 8 2 6
5 Total 76 47 29
CSPTCL + SLDC
1 Class I 179 163 16
2 Class II 265 199 66
3 Class III 1,557 754 803
4 Class IV 1,150 410 740
5 Total 3,151 1,526 1,625

A&G Expenses and R&M Expenses


CSPTCL submitted the Administrative & General (A&G) expenses and Repair &
Maintenance (R&M) expenses (excluding expenses on account of SLDC) for FY
2021-22 based on the audited accounts for FY 2021-22, as shown in the Table below:
Table 5-5: Gross R&M expenses and A&G expenses for FY 2021-22 as submitted by
CSPTCL (Rs. Crore)

FY 2021-22
Sr. No. Particulars
Actual
1 Gross A&G Expenses 50.33
2 Less: SLDC Expenses 0.90
3 CSPTCL Gross A&G Expenses 49.42
4 Gross R&M Expenses 64.14
5 Less: SLDC Expenses 1.70
6 CSPTCL Gross R&M Expenses 62.44

CSPTCL submitted that it has not considered expenses on account of Corporate


Social Responsibility (CSR) and shortage of inventory under A&G expenses.
CSPTCL has considered the capitalisation of A&G expenses as Rs. 0.98 Crore for FY
2021-22. CSPTCL submitted the comparison of actual O&M expenses vis-a-vis
O&M expenses approved in the MYT Order, as shown in the following Table:

116 CSERC Tariff Order FY 2022-23


Table 5-6: O&M Expenses as submitted by CSPTCL for FY 2021-22 (Rs. Crore)
Sr. Tariff
Particulars Petition
No. Order
1 Gross Employee Expenses 196.37 188.32
2 Gross A&G Expenses 46.37 49.42
3 Gross R&M Expenses 47.52 62.44
4 Interim Wage Relief amount -
5 Gross O&M Expenses (excluding SLDC) 287.37 300.18
6 Employee expenses capitalized 11.00
7 A&G Expenses capitalized 0.98
8 Net O&M Expenses (excluding SLDC) 287.37 288.21

CSPTCL requested the Commission to approve O&M expenses as per audited


accounts as shown in the above Table.
Sharing of gains and losses on account of O&M expenses
CSPTCL submitted that CSERC MYT Regulations, 2015 allows incentive/
disincentive for better/under performance in operational norms so that such efforts are
appropriately reflected, thereby, ensuring improved efficiency on a sustainable basis.
CSPTCL has computed gain and losses considering the Regulation 8, 11.2, and 13 of
the CSERC MYT Regulations 2015. Regulation 13.1 of CSERC MYT Regulations,
2015, as per amendment dated June 16, 2017 specifies as under:
“Provided further that employee cost shall not be factored in for sharing of gains or
losses on account of operation & maintenance expenses,”
Accordingly, the employee expenses have been considered based on actuals and have
not been subjected to sharing of gains or losses. CSPTCL requested the Commission
to approve actual employee expenses for FY 2021-22.
CSPTCL submitted that the normative A&G expenses and R&M expenses for FY
2021-22 have been computed as per the Regulations and the approach adopted by the
Commission in the previous Tariff Orders. CSPTCL has computed the base normative
A&G Expenses and R&M Expenses for FY 2021-22 by considering the normative
expenses for FY 2020-21 and Wholesale Price Index (WPI) of 13.00%. CSPTCL has
computed the normative A&G expenses and R&M Expenses for FY 2021-22 as Rs.
51.88 Crore and Rs. 53.16 Crore, respectively.
Additional O&M Expenses
CSPTCL submitted that as per Regulation 47.5(g) of CSERC MYT Regulations,
2015, claim for additional A&G expenses and R&M expenses on new transmission
lines/substations commissioned after March 31, 2016 have been determined based on
the methodology adopted by the Commission in the previous Tariff Orders.
Assets generated on account of consumer contribution have been taken as Rs. 1 in the
audited accounts as per accounting practice. However, assets so generated are being
maintained by CSPTCL and hence, qualify for additional R&M expenses and A&G
CSERC Tariff Order FY 2022-23 117
expenses against these assets. Total assets generated on account of consumer
contribution for FY 2018-19, FY 2019-20, FY 2020-21 and FY 2021-22 are Rs. 5.78
Crore, Rs. 13.60 Crore, Rs. 24.49 Crore and Rs. 60.36 Crore, respectively.
Accordingly, CSPTCL has computed additional normative A&G and R&M expenses
for FY 2021-22, as shown in the following Table:
Table 5-7: Additional Normative O&M Expenses as submitted by CSPTCL for FY
2021-22 (Rs. Crore.)
Sr. No. Particulars Formula FY 2021-22
1 Average of opening and closing
A 5278.41
GFA for previous FY 2020-21
2 Average of opening and closing
B 5,533.48
GFA for current FY 2021-22
3 Increase in GFA (%) C= (B-A)/A*100 4.83%
4 Normative A&G Expenses D 51.88
5 Normative R&M Expenses E 53.16
6 Additional A&G Expenses on
F=D*C 2.51
account of increase in GFA
7 Additional R&M Expenses on
G=E*C 2.57
account of increase in GFA

CSPTCL submitted the revised normative A&G Expenses and R&M Expenses for FY
2021-22 after adding Additional Normative expenses to base normative expenses, as
shown in the Table below:
Table 5-8: Revised Normative A&G Expenses and R&M Expenses as submitted by
CSPTCL for FY 2021-22 (Rs. Crore)

Particulars FY 2021-22
Normative A&G Expenses
Base Normative Expenses 51.88
Additional A&G Expenses 2.51
Total Normative A&G Expenses 54.38
Normative R&M Expenses
Base Normative Expenses 53.16
Additional R&M Expenses 2.57
Total Normative R&M Expenses 55.73

CSPTCL has submitted that normative A&G expenses and R&M expenses arrived
above and actual A&G expenses and R&M expenses have been considered for
computation of gain/loss. CSPTCL submitted the sharing of gain/(loss) for FY 2021-
22, as shown in the following Table:

118 CSERC Tariff Order FY 2022-23


Table 5-9: Sharing of gain/(loss) on A&G Expenses and R&M expenses as submitted by
CSPTCL for FY 2021-22 (Rs. Crore.)
Sr. FY 2021-22
Particulars
No. Normative Actual Gain/(Loss)
A Net A&G expenses 54.38 48.44 5.94
B Net R&M expenses 55.73 62.44 (6.71)
C Total 110.12 110.89 (0.77)
D CSPTCL share (1/2 of Total Gain/(Loss)) (0.38)

CSPTCL submitted that the prevalent norms for calculation of R&M expenses based
on WPI alone are not sufficient and should be linked with the growth in the asset base
of the Utility, and inflationary increase.

Consideration of Outsourced work under R&M Head


CSPTCL submitted that R&M works for FY 2021-22 have increased due to the
reason that EHV sub-stations of CSPTCL are being outsourced for operational
purposes (including cleaning, watch and ward). The details of the outsourced
expenses are as under:
Table 5-10: Details of Outsourced Expenses (Rs. Crore)
FY 2016- FY 2017- FY 2018- FY 2019- FY 2020- FY 2021-
Particulars
17 18 19 20 21 22
132 kV
10.35 14.41 24.47 24.63 24.26 32.78
Substations
220 kV
2.65 3.65 6.95 6.75 7.05 7.21
Substations
400 kV sub-
0.89 0.91 4.80
station
Grand total 13.00 18.06 31.42 32.27 32.21 44.81

The reason for considering these expenses under R&M expenses is that these
expenses have been incurred on R&M works for EHV sub-stations. There is no
separate account head for booking expenditure incurred on outsourced employees. If
regular employees of CSPTCL had been deployed for this purpose, then even more
expenditure (2 to 3 times) would have to be incurred. Similarly, for economic reasons,
it has employed various personnel through outsourcing against vacant posts in
ministerial cadre and wages of such personnel are booked under A&G head, instead
of salaries/employee expenses. The wages are variable and linked to price index. The
vacancies created by retirement are mostly filled up through outsourcing. Hence, the
expenditure incurred in the form of salaries and wages (plus a small profit) to
outsourced personnel should be treated as a separate line item and not be subject to
sharing of gain/(loss). It is pertinent to mention here that these wages are required to
be paid by CSPTCL to outsourced employees against the vacant posts of CSPTCL for
day-to-day operation (including cleaning, watch and ward) of existing/new EHV sub-
stations/offices, etc. Since, the nature of these expenses (wages) are similar to
employee expenses for regular employees, CSPTCL requested to consider these

CSERC Tariff Order FY 2022-23 119


expenses at par with employee expenses, only for the purpose of computation of gain
and loss of A&G expenses and R&M expenses.

Commission’s View
As regards O&M Expenses, Regulation 47.5 of the CSERC MYT Regulations, 2015
specifies as under:
“47.5 Operation and Maintenance expenses
Employee Cost
a) The employee cost, excluding pension fund contribution and impact
of pay revision arrears for the base year i.e. FY 16, shall be
derived on the basis of the normalized average of the actual
employee expenses excluding pension fund contribution and impact
of pay revision arrears available in the accounts for the previous
five (5) years immediately preceding the base year FY 16, subject
to prudence check by the Commission. Any other expense of
nonrecurring nature shall also be excluded while determining
normalized average for the previous five (5) years.
b) The normalization shall be done by applying last five year average
increase in Consumer Price Index (CPI) on year to year basis. The
average of normalized net present value for FY 2010-11 to FY 15,
shall then be used to project base year value for FY 16. The base
year value so arrived, shall be escalated by the above inflation rate
to estimate the employee expense (excluding impact of pension
fund contribution and pay revision, if any) for each year of the
Control period.
At the time of true up, the employee costs shall be considered
after taking into account the actual increase in CPI during the
year instead of projected inflation for that period.
Provided further that impact of pay revision (including arrears)
and pension fund contribution shall be allowed on actual during
the true-up as per accounts, subject to prudence check and any
other factor considered appropriate by the Commission.
A&G Expenses and R&M Expenses
c) The administrative and general expenses and repair and
maintenance expenses, for the base year i.e. FY 16, shall be
derived on the basis of the normalized average of the actual
administrative and general expenses and repair and maintenance
expenses, respectively available in the accounts for the previous
five (5) years immediately preceding the base year FY 16, subject
to prudence check by the Commission. Any expense of non-
recurring nature shall be excluded while determining normalized
average for the previous five (5) years.
d) The normalization shall be done by applying last five year average
increase in Wholesale Price Index (WPI) on year to year basis. The
average of normalized net present value for FY 2010-11 to FY 15,

120 CSERC Tariff Order FY 2022-23


shall then be used to project base year value for FY 16. The base
year value so arrived, shall be escalated by the above inflation rate
to estimate the administrative and general expense and repair and
maintenance expenses for each year of the Control period.
At the time of true up, the administrative and general expenses
and repair and maintenance expenses shall be considered after
taking into account the actual inflation instead of projected
inflation for that period.
e) The additional O&M Expenses on account of new transmission
lines/ substations commissioned after March 31, 2016 shall be
allowed by the Commission subject to prudence check at the time
of true-up exercise." (Emphasis added)
In accordance with the above-said Regulations, O&M Expenses had been approved in
the MYT Order for the Control Period. The above Regulations specify that at the time
of truing up, the O&M Expenses shall be considered after taking into account the
actual inflation instead of projected inflation for that period.
The Commission has considered escalation factor of 13.00% for R&M expenses and
A&G Expenses for FY 2021-22 based on applicable Wholesale Price Index (WPI).
Further, Regulation 47.5 (g) of the CSERC MYT Regulations, 2015, provides for
consideration of additional O&M expenses on account of new transmission lines/sub-
stations commissioned after March 31, 2016. In line with the methodology adopted by
the Commission in the previous Orders, the Commission has computed the additional
O&M expenses by considering approved GFA with the base O&M expenses allowed
for the previous year and in the same proportion for corresponding increase in GFA.
The Commission has also considered the GFA towards deposit works as submitted by
CSPTCL. The additional normative A&G expenses and R&M expenses on account of
new transmission lines and sub-stations for FY 2021-22 are computed as shown in the
Table below:
Table 5-11: Computation of Additional A&G expenses and R&M expenses for FY 2021-
22 (Rs. Crore)

Particulars Legend/Formula FY 2021-22


Average of Opening and Closing GFA for FY
A 5,278.41
Previous FY
Average of Opening and Closing GFA for
B 5,533.48
current FY
Increase in GFA (%) C=(B-A)/Ax100 4.83%
Normative A&G Expenses approved for FY D 51.88
Normative R&M Expenses approved for FY E 53.17
Additional A&G Expenses on account of
F=D x C 2.51
increase in GFA for FY
Additional R&M Expenses on account of
G=ExC 2.57
increase in GFA

CSERC Tariff Order FY 2022-23 121


For the purpose of true-up for FY 2021-22, the Commission approves the normative
A&G Expenses and R&M Expenses including additional A&G expenses and R&M
expenses on account of new transmission lines/sub-stations, as shown in the following
Table:
Table 5-12: Approved Normative A&G Expenses and R&M Expenses for FY 2021-22
(Rs. Crore)
Particulars Tariff Order Petition Revised
A&G Expenses 46.37 54.38 54.39
R&M Expenses 47.52 55.73 55.73
Grand total 93.89 110.11 110.12

The Commission has undertaken sharing of gains and losses of normative expenses
vis-à-vis actual expenses for FY 2021-22 in accordance with CSERC MYT
Regulations, 2015.
The actual Employee expenses have been approved based on audited accounts and
clarifications sought from CSPTCL, as shown in the Table below:
Table 5-13: Approved Actual Employee Expenses for FY 2021-22 (Rs. Crore)
Sr.
Particulars Petition Approved
No.
Gross Employee Expenses (CSPTCL +
1 197.78 197.78
SLDC) excluding terminal benefits
2 Less: SLDC Employee Expenses 9.46 9.46
3 Gross Employee Expenses (excluding SLDC) 188.32 188.32
4 Less: Employee Cost Capitalized 11.00 11.00
5 Net Employee Expenses 177.32 177.32

The Commission has approved actual A&G expenses and R&M expenses for FY
2021-22 considering the audited annual accounts, as shown in the following Table:
Table 5-14: Approved Actual A&G Expenses and R&M Expenses for FY 2021-22 (Rs.
Crore)
Sr.
Particulars Petition Approved
No.
1 Gross A&G Expenses 50.33 50.33
2 Less: SLDC Expenses 0.90 0.90
3 Gross A&G Expenses (Excluding SLDC) 49.43 49.43
4 A&G Expenses Capitalized 0.98 0.98
5 Net A&G Expenses 48.45 48.45
6 Gross R&M Expenses 64.14 64.14
7 Less: SLDC Expenses 1.70 1.70
8 Gross R&M Expenses (Excluding SLDC) 62.44 62.44
9 R&M Expenses Capitalized
10 Net R&M Expenses 62.44 62.44

122 CSERC Tariff Order FY 2022-23


As regards the sharing of gains and losses, the following provision has been inserted
in Regulation 13.1 by the First Amendment to the CSERC MYT Regulations, 2015 on
June 16, 2017:
“Provided further that employee cost shall not be factored in for sharing of gains or
losses on account of operations and maintenance expenses …”
Accordingly, the Commission approves the Employee Expenses at actuals for
FY 2021-22.
Further, the Commission notes that CSPTCL in its subsequent submission, has
requested the Commission to consider expenses of outsourcing and sub-contracting
manpower as a separate line item instead of under R&M Expenses or A&G expenses,
and not subject the same to sharing of efficiency gains or losses. According to the
CSERC MYT Regulations, 2015, such expenses cannot be a part of employee
expenses, and shall be booked under A&G expenses or R&M expenses, as
appropriate.
Accordingly, the sharing of gains and losses in O&M expenses, computed after final
true-up for FY 2021-22, is shown in the following Table:
Table 5-15: Sharing of gain/(loss) on A&G Expenses and R&M expenses for FY 2021-22
as approved by the Commission (Rs. Crore)
Sr.
Particulars Normative Actual Gain/ (Loss)
No.
A Net A&G expenses 54.39 48.45 5.94
B Net R&M expenses 55.73 62.44 (6.70)
C Total Gain/(Loss) (0.77)
D CSPTCL share (1/2 of Total Gain/(Loss)) (0.38)

5.5 Contribution to Pension and Gratuity Fund


CSPTCL’s Submission
CSPTCL submitted that the Commission, in the Tariff Order dated 2nd August, 2021,
allowed contribution to Pension and Gratuity (P&G) fund of Rs. 87.65 Crore for FY
2021-22 net of SLDC. Accordingly, CSPTCL has made P&G contribution of Rs.
87.65 Crore.

Commission’s View
The Commission approves the actual Contribution to P&G Fund for FY 2021-22 as
submitted by CSPTCL, as shown in the following Table:
Table 5-16: Contribution to P&G Fund for FY 2021-22 as approved by the Commission
(Rs. Crore)
Tariff Order
Particulars dated Petition Approved
02.08.2021
Contribution to P&G Fund 87.65 87.65 87.65

CSERC Tariff Order FY 2022-23 123


5.6 Gross Fixed Assets
CSPTCL’s Submission
CSPTCL submitted that the Commission, in the MYT Order for the Control Period
from FY 2016-17 to FY 2020-21 dated April 30, 2016, had approved the
methodology for determination of capital structure into consumer contribution, debt
and equity. The capital structure for FY 2021-22 has been considered as follows:
 The opening Capital Works in Progress (CWIP) of Rs. 494.93 Crore for FY
2021-22 has been considered equal to the closing CWIP of FY 2020-21;
 Closing CWIP of Rs. 589.21 Crore has been considered as per the audited
accounts for FY 2021-22;
 The actual loan addition of Rs. 268.75 Crore has been considered as per the
audited accounts for FY 2021-22;
 GFA addition of Rs. 134.83 Crore for FY 2021-22 (net of GFA addition for
SLDC) have been considered as per audited accounts;
 Assets generated on account of Consumer Contribution has been taken as Nil,
considering their value as Rs.1 only as per Accounting Standard;
 The normative debt: equity ratio has been considered as 70:30 for additional
capitalisation during FY 2021-22 as per the CSERC MYT Regulations, 2015.
CSPTCL submitted that assets of Rs. 134.83 Crore created during FY 2021-22 is a
part of GFA mentioned in Audited Accounts of FY 2021-22, which excludes asset
created through consumer contribution/grant. However, as per Audited Accounts, it is
reflected that PSDF grants received during FY 2021-22 is Rs. 38.23 Crore. The
amount received from grants has not been converted to assets till date and as per
accounting practice, assets created due to consumer contribution is taken as Re. 1
irrespective of actual value of asset.
CSPTCL submitted the means of finance for GFA addition at normative debt:equity
ratio of 70:30. Accordingly, CSPTCL submitted the debt amount of Rs. 94.38 Crore
and Equity amount of Rs. 40.45 Crore for FY 2021-22. CSPTCL requested the
Commission to approve the capital structure and means of finance including GFA
addition for FY 2021-22 as per its submissions.

Commission’s View
In the previous Tariff Order, the Commission has approved the closing GFA as Rs.
5,435.88 Crore after true-up for FY 2020-21. The Commission has accordingly
considered the same amount as opening GFA for FY 2021-22.
As regards GFA addition during the year, CSPTCL was asked to submit scheme-wise
details of asset addition for FY 2021-22 with respect to the scheme-wise capitalisation
approved for FY 2021-22. In the reply, CSPTCL submitted accounting head-wise
details for capitalisation for FY 2021-22.
The Commission notes that audited accounts for FY 2021-22 indicate the
capitalisation of Rs. 134.83 Crore, which is capitalisation of CSPTCL only as
capitalisation by CSLDC during FY 2021-22 is Rs. 0.09 Crore. Accordingly, the
Commission has considered the capitalisation of Rs. 134.83 Crore for FY 2021-22.

124 CSERC Tariff Order FY 2022-23


The Commission approves the GFA addition and its funding for FY 2021-22 as
shown in the following Table:
Table 5-17: Approved GFA Addition and Means of Finance for FY 2021-22 (Rs. Crore)
Sr. No. Particulars Petition Approved
1 GFA Addition 134.83 134.83
Means of Finance
2 Consumer Contribution 0.00 0.00
3 Equity 40.45 40.45
4 Debt 94.38 94.38
5 Total Capitalisation 134.83 134.83

5.7 Depreciation
CSPTCL’s Submission
CSPTCL submitted that it has computed depreciation of Rs. 256.75 Crore FY 2021-
22, in accordance with Regulation 24 of the CSERC MYT Regulations, 2015 and the
methodology considered by the Commission in the past. CSPTCL requested the
Commission to approve the same in the final true-up of ARR for FY 2021-22.

Commission’s View
The Commission has approved the depreciation in accordance with the MYT
Regulations, 2015 and approach adopted in the past Orders. The closing GFA for FY
2020-21, as approved in the true up for FY 2020-21, has been considered as the
opening GFA for FY 2021-22. The additional GFA as well as the addition of Grants
and Consumer Contribution in GFA has been considered as approved by the
Commission. The weighted average depreciation rate of 5.26%, computed on the
basis of deprecation rates specified in the CSERC MYT Regulations, 2015, has been
considered for FY 2021-22. Depreciation on assets due to Consumer Contribution and
grants equates to Rs. 2.84 Crore for FY 2021-22.
CSPTCL has submitted the depreciation on fully depreciated assets during the year as
Rs. 29.75 Crore for FY 2021-22 and the same has been considered by the
Commission. The depreciation computed by the Commission for FY 2021-22 is
shown in the following Table:
Table 5-18: Approved Depreciation for FY 2021-22 (Rs. Crore)

Sr. Tariff
Particulars Petition Approved
No. Order
1 Opening GFA excluding CSLDC 5,258.68 5,435.88 5,435.88
2 Add: Capitalization during the year 151.5 134.83 134.83
3 GFA at the end of the year excluding
5,410.18 5,570.71 5,570.71
CSLDC
4 Average GFA for the year 5,334.43 5,503.29 5,503.30
5 Depreciation Rate 5.26% 5.26% 5.26%

CSERC Tariff Order FY 2022-23 125


Sr. Tariff
Particulars Petition Approved
No. Order
6 Depreciation @ applicable rates as per
280.50 289.33 289.33
Regulations
7 Opening consumer contribution 54.04 54.04
8 Addition: consumer contribution during
0
the year
9 Closing consumer contribution 0 54.04 54.04
10 Average consumer contribution - 54.04 54.04
11 Less: Depreciation on Consumer
2.84 2.84 2.84
Contribution and grants
12 Less: Depreciation on fully depreciated
26.32 29.75 29.75
assets
13 Net Depreciation 251.33 256.75 256.75

5.8 Interest on Loan


CSPTCL’s Submission
CSPTCL submitted that it has calculated interest and finance charges as per
Regulation 23 of the CSERC MYT Regulations, 2015. CSPTCL has submitted details
of actual loan for FY 2021-22 as per the audited accounts. CSPTCL has considered
the approved closing normative loan balance for FY 2020-21 as per the true-up Order,
as the opening normative loan balance for FY 2021-22. The debt component of 70%
of GFA addition after deduction of grants during FY 2021-22 has been considered as
the normative loan addition during the year. The allowable depreciation for FY 2021-
22 has been considered as the normative repayment for the current year. The rate of
interest has been computed in accordance with Regulation 23.5. The actual weighted
average interest rate of 9.97% for FY 2021-22 has been considered for computation of
the interest on loan. CSPTCL requested the Commission to approve Interest on Loan
of Rs. 187.61 Crore for FY 2021-22.

Commission’s View
The Commission has approved interest on loan capital for FY 2021-22 as per
Regulation 23 of the CSERC MYT Regulations, 2015.
The Commission has considered the closing net normative loan balance for FY 2020-
21, as approved after True-up, as the opening net normative loan balance for FY
2021-22. The addition of normative loan for FY 2021-22 has been considered based
on debt component towards the actual capitalisation of during the year, as approved
earlier in this Chapter. The repayment has been considered equal to net depreciation
approved for FY 2021-22 in this Order.
The Commission has computed the weighted average rate of interest of 9.97% for FY
2021-22, as per Regulation 23.5 of the CSERC MYT Regulations, 2015. Accordingly,
the normative interest on loan approved for FY 2021-22 is shown in the Table below:

126 CSERC Tariff Order FY 2022-23


Table 5-19: Approved Interest on Loan for FY 2021-22 (Rs. Crore)
Sr.
Particulars Tariff Order Petition Approved
No.
1 Total Opening Net Loan 1,842.76 1,962.56 1,962.56
2 Repayment during the period 251.33 256.75 256.75
Additional Capitalization of
3 106.05 94.38 94.38
Borrowed Loan during the year
4 Total Closing Net Loan 1,697.48 1,800.19 1,800.19
5 Average Loan during the year 1,770.12 1,881.38 1,881.37
6 Weighted Average Interest Rate 10.02% 9.97% 9.97%
7 Interest Expenses 177.34 187.61 187.54

5.9 Return on Equity (RoE) and Income Tax


CSPTCL’s Submission
CSPTCL has computed Return on Equity (RoE) as per Regulation 22 of the CSERC
MYT Regulations, 2015, using the base rate of Return on Equity of 15.50%. The
Income Tax has been separately claimed based on actual Income Tax paid during the
year. CSPTCL has claimed the Income Tax of Rs. 9.14 Crore for FY 2021-22.
CSPTCL has considered the closing permissible equity balance of FY 2020-21, as
approved in the true-up Order, as the opening permissible equity balance for FY
2021-22. The equity addition has been considered as 30% of the actual capitalisation
during the year. CSPTCL requested the Commission to approve RoE of Rs. 226.48
Crore for
FY 2021-22.

Commission’s View
Regulation 22 of the MYT Regulations, 2015 specifies that RoE shall be computed by
grossing up the base rate with the prevailing MAT rate of the base year for projection
purposes. CSPTCL has paid Income Tax of Rs. 9.14 Crore for FY 2021-22. In the
previous Tariff Orders, the Commission has allowed Income Tax paid separately,
rather than grossing up the RoE. The Commission notes that CSPTCL has also
requested for separate approval of actual Income Tax paid. Accordingly, the
Commission has approved RoE at base rate of 15.50% as per Regulation 22 of the
CSERC MYT Regulations, 2015 and allowed the Income Tax separately.
For computation of RoE, the closing equity as approved after True-up for FY 2020-21
has been considered as opening equity for FY 2021-22. The equity addition has been
considered based on the actual capitalisation as approved earlier in this Order. The
Commission approves the RoE for FY 2021-22 as shown in the following Table:
Table 5-20: Approved Return on Equity for FY 2021-22 (Rs. Crore)
Sr. Tariff Approv
Particulars Petition
No. Order ed
1 1,387.3 1,440. 1,44
Permissible Equity in Opening GFA
0 96 0.96
2 Addition of Permissible Equity 40.4
45.45 40.45
during the year 5
3 Permissible Equity in Closing GFA 1,433.2 1,481. 1,48

CSERC Tariff Order FY 2022-23 127


Sr. Tariff Approv
Particulars Petition
No. Order ed
5 41 1.41
4 Average Gross Permissible Equity 1461. 1461
1410.53
during the year 19 .19
5 15.50 15.5
Rate of Return on Equity 15.50%
% 0%
6 226.4 226.
Return on Equity 218.63
8 48

As regards Income Tax, CSPTCL was asked to submit the detailed computation of
Income Tax and documentary evidence related to actual payment, viz., Income tax
receipt, challans, etc. for prudence check of Income Tax paid for FY 2021-22.
CSPTCL submitted computation of Income Tax, Income Tax challans and other
documentary evidences for FY 2021-22. Further, CSPTCL clarified that no
adjustment towards MAT credit has been made during FY 2021-22 and during the
year FY 2021-22, CSPTCL has received Nil refund of Income Tax.

5.10 Interest on Working Capital


CSPTCL’s Submission
For computation of Interest on Working Capital (IoWC) for FY 2021-22, CSPTCL
has considered one month of O&M expenses, maintenance spares at 40% of R&M
expenses, and receivables equivalent to one month of revenue billed for computing
the working capital requirement. CSPTCL has considered the interest rate of 10.90%
(i.e., 7.40% - SBI Base Rate on 1st April 2021 plus 350 basis points) for FY 2021-22.
CSPTCL requested the Commission to approve IoWC of Rs. 14.13 Crore for
FY 2021-22.

Commission’s View
The Commission has computed IoWC in accordance with Regulation 25 of the MYT
Regulations, 2015. For computation of working capital requirement as per the formula
specified in the CSERC MYT Regulations, 2015, the Commission has considered the
revised normative value of O&M expenses as approved in this Order. Further, the
receivables have been considered based on the actual revenue billed by CSPTCL
during FY 2021-22. The interest rate has been considered as per Regulation 25.4 of
the MYT Regulations, 2015, i.e., 10.90% (7.4% + 3.5%) for FY 2021-22. The
normative IoWC approved by the Commission is shown in the Table below:
Table 5-21: Approved Interest on Working Capital for FY 2021-22 (Rs. Crore)
Sr. Tariff
Particulars Petition Approved
No. Order
1 O&M expenses for One Month 23.67 24.02 23.87
2 Maintenance Spares @ 40% of R&M Expenses 17.75 24.98 22.29
3 Receivables @ 1 Month 84.94 80.64 80.64
4 Total Working Capital requirement 126.36 129.63 126.80
5 Less: Security Deposit from Transmission Users

128 CSERC Tariff Order FY 2022-23


Sr. Tariff
Particulars Petition Approved
No. Order
6 Net Working Capital Requirement 126.36 129.63 126.80
7 Rate of Interest on Working Capital 10.90% 10.90% 10.90%
8 Interest on Working Capital 13.77 14.13 13.82

5.11 Non-Tariff Income


CSPTCL’s Submission
CSPTCL submitted the Non-Tariff Income of Rs. 16.85 Crore for FY 2021-22 based
on audited accounts and requested the Commission to approve the same.

Commission’s View
For the purpose of true-up for FY 2021-22, the Commission has considered the Non-
Tariff Income for Transmission Business as per Segmental Notes of Accounts for FY
2021-22. Accordingly, the Commission has considered Non-Tariff income of Rs.
16.85 Crore for FY 2021-22, as shown in the Table below:
Table 5-22: Approved Non-Tariff Income for FY 2021-22 (Rs. Crore)

Sr. No. Particulars Tariff Order Petition Approved


1 Non-Tariff Income 13.50 16.85 16.85

5.12 Incentive/Penalty on Transmission System Availability Factor (TSAF)


CSPTCL’s Submission
CSPTCL submitted that Target Availability of the transmission system is specified in
Regulation 51 of the CSERC MYT Regulations, 2015, for incentive/penalty
payable/levied to a Transmission Licensee. In the MYT Order dated 30th April 2016,
the Commission has approved the annual Target Availability factor for
incentive/penalty as 99% and stipulated the modalities for computation of
incentive/penalty on account of actual Transmission System Availability Factor
(TSAF).
CSPTCL submitted that it has achieved TSAF of 99.79% for FY 2021-22.
Accordingly, CSPTCL has claimed the incentive of Rs. 4.00 Crore for FY 2021-22.

Commission’s View
As regards Incentive/Penalty calculation related to the TSAF, the CSERC MYT
Regulations, 2015 specifies as under:
“51. INCENTIVE/ PENALTY TO TRANSMISSION LICENSEE
Incentive/ Penalty may be payable/levied to a transmission licensee in case the
availability of the transmission system during a year deviates from the target
availability, which shall be specified by the Commission in the MYT Order for
the next Control Period.”
In the MYT Order for the Control Period from FY 2016-17 to FY 2020-21, the
Commission stipulated as under:

CSERC Tariff Order FY 2022-23 129


“10.3.11 Incentive/Penalty Calculation
A. As per Clause 51 of the MYT Regulations, 2015, target availability of
transmission system has to be specified for the control period for
incentive/penalty payable/levied to a transmission licensee.
B. Annual target availability factor for incentive/penalty consideration shall
be 99% for entire MYT Control period from FY 2016-17 to FY 2020-21:
Provided further that no incentive/penalty shall be payable for
availability beyond 99.75%:
C. The transmission licensee shall be entitled to incentive/penalty on
achieving the annual availability beyond/lower than the target
availability in accordance with the following formula:
Incentive/Penalty = Annual Fixed Charges for that year x (Annual
availability achieved – Target availability) / Target availability
D. Incentive/Penalty shall be shared equally (50:50) between the
transmission licensee and beneficiaries.”
The Incentive/Penalty has been allowed in accordance with the above said principle
specified in the Regulations.
The Commission has validated the actual TSAF based on CSLDC Certificate
submitted for FY 2021-22. The Commission notes that the actual TSAF duly certified
by CSLDC is 99.77% for FY 2021-22, which is higher than the Target TSAF. Hence,
CSPTCL is entitled for incentive.
Accordingly, the Commission approves the Incentive on account of TSAF for FY
2021-22, as shown in the Table below:
Table 5-23: Approved Incentive for Higher Transmission System Availability for FY
2021-22 (Rs. Crore)
Sr. No. Particulars Petition Approved
1 Annual TSAF (%) 99.79% 99.77%
2 Target TSAF (%) 99.00% 99.00%
Maximum TSAF that can be considered for
3 99.75% 99.75%
incentive
4 Incentive/(Penalty) 8.01 8.00
5 Sharing of gain/(loss) (50%) 4.00 4.00

5.13 Aggregate Revenue Requirement (ARR)


Based on the above, the ARR approved after true-up for FY 2021-22 is shown in the
Table below:
Table 5-24: Approved ARR after true-up for FY 2021-22 (Rs. Crore)

Sr.
Particulars Tariff Order Petition Approved
No.
1 Employee Expenses 196.37 188.32 188.32
2 A&G Expenses 46.37 49.42 49.43

130 CSERC Tariff Order FY 2022-23


Sr.
Particulars Tariff Order Petition Approved
No.
3 R&M Expenses 47.52 62.44 62.44
4 Terminal Benefits 87.65 87.65 87.65
Less: Capitalization of Employee
5 11.98 11.98
and A&G Expenses
6 Depreciation 251.33 256.75 256.75
7 Interest on Loan 177.34 187.61 187.54
8 Interest on Working capital 14.03 14.13 13.82
10 Return on Equity 218.63 226.48 226.48
Gain/(Loss) on sharing O&M
11 (0.38) (0.38)
efficiency
Incentive on Transmission
12 4.00 4.00
Availability
13 Current Tax 9.14 9.14
14 Total 1,039.24 1,073.58 1,073.21
15 Less: Non-Tariff Income 13.5 16.85 16.85
Aggregate Revenue
16 1,025.74 1,056.73 1,056.36
Requirement (ARR)

5.14 Revenue Gap/(Surplus) for FY 2021-22


CSPTCL’s Submission
CSPTCL submitted the Revenue Gap/(Surplus) for FY 2021-22, as shown in the
following Table:
Table 5-25: Revenue Gap/(Surplus) submitted by CSPTCL for FY 2021-22 (Rs. Crore)

Sr. No. Particulars FY 2021-22


AFC for FY 2021-22 as approved in Tariff Order
1 1025.74
dated 02.08.2021
Surplus adjusted with carrying cost up to FY 2021-22
2 46.06
as approved in Tariff Order dated 02.08.2021
3 Adjusted ARR for FY 2021-22 979.63
4 ARR determined based on True-up for FY 2021-22 1056.73
5 Gap/(Surplus) 30.99

As per CERC Order dated 16.02.2016 in Petition No. 245/TT/2013, CSPTCL has
executed Revenue Sharing Agreement (RSA) and Transmission Service Agreement
(TSA) with Power Grid Corporation of India Limited (PGCIL) on 02.08.2017 for
disbursement of transmission charges by PGCIL in CSPTCL account in respect of

CSERC Tariff Order FY 2022-23 131


220 kV Natural Inter-State Transmission Lines belonging to CSPTCL. However,
CSPTCL has received Nil amount from PGCIL during FY 2021-22 in this regard.
CSPTCL requested the Commission to approve the Revenue Gap of Rs. 30.99 Crore
for FY 2021-22.

Commission’s View
The Commission has computed the Revenue Gap/(Surplus) after true-up for
FY 2021-22 for CSPTCL, as shown in the Table below:
Table 5-26: Approved Revenue Gap/(Surplus) for FY 2021-22 (Rs. Crore)
Sr.
Particulars Approved
No.
1 Revenue from Transmission Charges for FY 2021-22 967.64
Surplus of adjusted with holding cost up to FY 2021-22 as 46.06
2
approved in tariff order dated 02.08.2021
3 Total Revenue for FY 2021-22 1,013.70
Actual ARR determined based on Final True-up for FY 1,056.36
4
2021-22
5 Revenue Gap/(Surplus) (2-1) 42.66

The Commission approves the Revenue Gap of Rs. 42.66 Crore after true-up for
CSPTCL for FY 2021-22. This Revenue Gap has been adjusted in the revenue
requirement of CSPDCL for FY 2023-24 along with holding cost.

5.15 Adjusted ARR for FY 2023-24


CSPTCL’s Submission
CSPTCL has submitted cumulative gap for FY 2023-24, as shown in the Table below:
Table 5-27: Cumulative Gap/(Surplus) submitted by CSPTCL for FY 2023-24 (Rs.
Crore)
Sr. No. Particulars FY 2021-22 FY 2022-23 FY 2023-24
1 Opening Gap 0 32.68 36.24
2 Standalone Gap 30.99 0 36.24
3 Closing Gap 30.99 32.68 0.00
4 Interest Rate 10.90% 10.90% 10.90%
5 Carrying Cost 1.69 3.56 1.98
6 Total Closing Gap 32.68 36.24 38.22

Commission’s View
The Commission has considered the Revenue Gap of Rs. 42.66 Crore approved after
true up for FY 2021-22 along with carrying cost, which amounts to Rs. 51.24 Crore.
This Revenue Gap has been adjusted against the approved ARR for FY 2023-24 as
shown in the Table below:

132 CSERC Tariff Order FY 2022-23


Table 5-28: Adjusted approved ARR for FY 2023-24 (Rs. Crore)
Sr. No. Particulars Petition Approved
ARR approved vide Order dated 13.04.2022 for
1 1155.61 1155.61
FY 2023-24
Plus: FY 2021-22 deficit with carrying cost till
2 38.22 51.24
FY 2023-24
3 Adjusted ARR for FY 2023-24 1193.83 1206.85

5.16 Transmission Charges for FY 2023-24


CSPTCL’s Submission
CSPTCL submitted that it has computed net ARR for FY 2023-24 by considering the
provisions of Regulation 71 of the CSERC MYT Regulations, 2021.
CSPTCL submitted that as per Clause 33 of CSERC (Connectivity and Intra-State
Open Access) Regulations, 2011 and the amendment in the CSERC (Connectivity and
Intra-State Open Access) (First Amendment) Regulations, 2012, Open Access charges
for using the State Grid have been defined. CSPTCL has determined the short-term
Open Access charges for FY 2023-24 by considering the projected maximum demand
of 5401 MW. The estimated energy input to be handled by CSPTCL‟s system for FY
2023-24, based on load factor of 70% on maximum demand met, has been considered
as 33118.93 MU.

Commission’s View
Regulations 71.2 and 71.2 of the CSERC MYT Regulations, 2021 specify as under:
“71.1. Annual Transmission Charges for each year of the Control Period: The
Annual Transmission Charges for each financial year of the Control Period shall
provide for the recovery of the Aggregate Revenue Requirement of the
transmission licensee / STU for the respective financial year of the Control
Period, reduced by the amount of Non-Tariff Income and income from other
business, as approved by the Commission:
71.2. The Annual Transmission Charges of the transmission licensee shall be
determined by the Commission on the basis of an application for determination of
Aggregate Revenue Requirement made by the transmission licensee in
accordance with Chapter- 2 of this Regulation.”
As per the CSERC MYT Regulations, 2021, the annual transmission charges (fixed
cost) shall be recovered from the users of CSPTCL‟s system on a monthly basis as per
the methodology specified in the CSERC Open Access Regulations, 2011. According
to the CSERC Open Access Regulations, 2011, the basis of sharing monthly
transmission charge shall be maximum demand in MW served by CSPTCL‟s system
in the previous financial year.
In the response of the Commission‟s query, CSPTCL submitted the justification of
projecting Maximum Demand of 5401 MW for FY 2023-24. Accordingly, the
Commission considered Maximum Demand in the State for FY 2023-24 as 5401
MW. The estimated energy input to be handled by CSPTCL‟s system for FY 2023-24,
based on load factor of 70% on Maximum Demand met, is computed as 33209.67

CSERC Tariff Order FY 2022-23 133


MU. Accordingly, the Transmission Charges for STOA for FY 2023-24 have been
determined as shown in the Table below:
Table 5-29: Approved STOA Charges submitted by CSPTCL for FY 2023-24 (Rs.
Crore)
Sr. No. Particulars Petition Approved
1 ARR approved vide Order dated 13.04.2022 1155.61 1155.61
for FY 2023-24
2 Plus: FY 2021-22 deficit with carrying cost 38.22 51.24
till FY 2023-24
3 Adjusted ARR for FY 2023-24 1193.83 1206.85
4 Max Demand Projected in MW 5401 5401
5 Energy Input in MU considering 70% Load 33118.93 33209.67
Factor
6 STOA Charges in Paisa/Kwh 36.05 36.34

134 CSERC Tariff Order FY 2022-23


6 TRUE-UP OF ARR FOR FY 2021-22 FOR CSLDC
6.1 Background
The Commission issued the MYT Order on April 13, 2022 approving the ARR of
CSLDC for the Control Period from FY 2022-23 to FY 2024-25 and SLDC Charges
for FY 2022-23. The Commission has determined the ARR and Tariff for FY 2021-22
on August 02, 2021 and the final true up of ARR for FY 2021-22 had been carried out
by comparing actual performance with the values as approved in Order dated August
02, 2021.
Now, CSLDC has submitted the present Petition for true-up of ARR for FY 2021-22
based on the Audited Accounts of FY 2021-22.
In accordance with Regulation 10.4 of the CSERC MYT Regulations, 2015, the
Commission has undertaken the true-up of FY 2021-22 for CSLDC based on Audited
Accounts and Segmental Notes submitted by CSLDC.
In this Chapter, the Commission has analysed all the elements of actual expenditure
and revenue of CSLDC for FY 2021-22 and undertaken the final true-up of expenses
and revenue. The Commission has approved the sharing of gains and losses on
account of controllable factors between CSLDC and its beneficiaries, in accordance
with Regulation 13 of the CSERC MYT Regulations, 2015.

6.2 Annual Charges for SLDC


Regulation 74.1 of the CSERC MYT Regulations, 2015 specifies the components of
Annual Charges for SLDC as under:
(a) Operation and Maintenance Expenses;
(b) Contribution to Pension and Gratuity Fund;
(c) Return on Equity;
(d) Interest on loan capital;
(e) Depreciation; and
(f) Interest on Working Capital.

6.3 Operation and Maintenance (O&M) expenses


CSLDC’s Submission
CSLDC has claimed O&M expenses in accordance with Regulation 47.5 of CSERC
MYT Regulations, 2015. CSLDC submitted that O&M Expenses includes Employee
expenses, A&G expenses, and R&M expenses. CSLDC has considered O&M
expenses for FY 2021-22, as shown in the Table below:
Table 6-1: O&M Expenses for FY 2021-22 (Rs. Crore)
Sr. No. Particulars FY 2021-22
1 Gross Employee Expenses 9.46
2 Gross A&G Expenses 0.90
3 Gross R&M Expenses 1.70
4 Total O&M Expenses 12.06

CSERC Tariff Order FY 2022-23 135


Also, CSLDC submitted the details of sanctioned employee strength, current
employee strength, and vacant positions for different class of employees, as on March
31, 2022. The total sanctioned strength of different class of employees of CSLDC is
76 out of which 47 are currently working and balance 29 are envisaged to be filled in
the coming FYs, as shown in the Table below:
Table 6-2: Employee strength of CSLDC as on 31st March 2022
Sr.
Particulars Sanctioned Working Vacant
No.
1 Class I 20 19 1
2 Class II 24 12 12
3 Class III 24 14 10
4 Class IV 8 2 6
5 Total 76 47 29

CSLDC requested to approve actual O&M Expenses of Rs. 12.06 Crore for
FY 2021-22.

Sharing of gain and losses on account of O&M Expenses


For computation of gain and losses, CSLDC has considered provisions of Regulations
8, 11.2 and 13 of MYT Regulations, 2015.
As per the MYT Regulations, 2015 and the subsequent amendment, the Employee
expenses have been considered based on actuals and have not been subjected to
sharing of gains or losses. A&G expenses and R&M expenses have been subjected to
sharing of gains/losses as per Regulation 47.5 of the MYT Regulations, 2015.
Accordingly, CSLDC has computed the normative A&G expenses and R&M
expenses for FY 2021-22 by applying WPI escalation factor of 13% on approved
expenses of FY 2020-21. The normative A&G expenses and R&M expenses for FY
2021-22, as submitted by CSLDC are shown in the Table below:
Table 6-3: Normative A&G Expenses and R&M Expenses for FY 2021-22 as
submitted by CSLDC (Rs. Crore)
Sr. No. Particulars FY 2021-22
1 Normative A&G Expenses 1.38
2 Normative R&M Expenses 2.01

The normative A&G expenses and R&M expenses have been considered for the
purpose of sharing of gains/losses for FY 2021-22. The actual A&G expenses and
R&M expenses are Rs. 0.90 Crore and Rs. 1.70 Crore (net of capitalisation),
respectively, for FY 2021-22. The same have been considered for sharing of
gain/(loss) as shown in the Table below:

136 CSERC Tariff Order FY 2022-23


Table 6-4: Sharing of gain/(loss) on A&G expenses and R&M expenses for FY
2021-22 as submitted by CSLDC (Rs. Crore)
Sr.
Particulars Normative Actual Gain/(Loss)
No.
1 Net A&G expenses 1.38 0.90 0.48
2 Net R&M expenses 2.01 1.70 0.32
3 Total 3.39 2.60 0.79
CSLDC share (1/2 of Total
4 0.40
Gain/(Loss))

CSLDC submitted the sharing of gains of Rs. 0.40 Crore on account of sharing of
normative A&G expenses and R&M expenses vis-à-vis actual expenses in the true-up
of ARR for FY 2021-22.

Commission’s View
Regulation 47.5 of the CSERC MYT Regulations, 2015 specifies the basis for
computation of normative O&M expenses and the method of sharing the efficiency
gains/losses vis-à-vis actual O&M expenses, as reproduced in the earlier Chapter.
The Commission, in the MYT Order, had approved O&M Expenses for the Control
Period in accordance with the said Regulations, which specify that at the time of
truing up, the O&M expenses shall be considered after taking into account the actual
inflation over the approved O&M expenses of base-year/previous year.
Accordingly, the Commission has computed the revised normative O&M expenses
for FY 2021-22 by applying the actual inflation over base-year‟s approved O&M
expenses. The Commission has considered the WPI as per the MYT Regulations,
2015 and, accordingly, computed escalation factor of 13% for R&M expenses and
A&G Expenses for FY 2021-22. Accordingly, the normative O&M Expenses
approved for FY 2021-22 are shown in the Table below:
Table 6-5: Approved Normative O&M Expenses for FY 2021-22 (Rs. Crore)
Revised Normative
Particulars Tariff Order Petition
Expenses
A&G Expenses 1.24 1.38 1.37
R&M Expenses 1.81 2.01 2.01

The Commission has considered actual O&M expenses for FY 2021-22 as per audited
accounts and Segmental Notes, as submitted by CSLDC. Accordingly, the
Commission approves actual O&M Expenses of Rs. 12.06 Crore for FY 2021-22.
The Commission has undertaken sharing of gains and losses of normative expenses
vis-à-vis actual expenses for FY 2021-22, as per MYT Regulations, 2015. As regards
the sharing of gains and losses, the following provision has been inserted in
Regulation 13.1 by the First Amendment to the MYT Regulations, 2015 on June 16,
2017:
“Provided further that employee cost shall not be factored in for sharing of
gains or losses on account of operations and maintenance expenses…”

CSERC Tariff Order FY 2022-23 137


Accordingly, the Commission approves the Employee Expenses at actuals as Rs. 9.46
Crore for FY 2021-22.
As CSPTCL and CSLDC do not have separate accounts, the entire capitalization of
O&M expenses has been considered in CSPTCL‟s Petition. The Commission has
considered the actual A&G expenses and R&M expenses net of capitalisation for
sharing of gains and losses for FY 2021-22, as shown in the Table below:
Table 6-6: Sharing of gain/(loss) on A&G expenses and R&M expenses for FY
2021-22 as approved by the Commission (Rs. Crore)
Sr.
Particulars Normative Actual Gain/(Loss)
No.
1 Net A&G expenses 1.37 0.90 0.47
2 Net R&M expenses 2.01 1.70 0.31
3 Total 3.39 2.60 0.78
CSLDC share (1/2 of Total 0.39
4
Gain/(Loss))

In this Order, the Commission approves the O&M expenses based on audited
accounts for FY 2021-22. Further, the Commission approves sharing of gains of Rs.
0.39 Crore for FY 2021-22.

6.4 Contribution to Pension and Gratuity Fund


CSLDC’s Submission
CSLDC submitted that the Commission, in the Tariff Order, had allowed Contribution
to Pension and Gratuity (P&G) fund of Rs. 1.80 Crore for FY 2021-22. CSLDC has
considered the same amount as actual contribution and requested the Commission to
approve the same.

Commission’s View
The Commission has approved the actual Contribution to Pension and Gratuity Fund
of Rs. 1.80 Crore for FY 2021-22 as claimed by CSLDC.

6.5 Gross Fixed Assets and Means of Finance


CSLDC submitted that the Commission in MYT Order approved the methodology for
determination of capital structure of GFA into debt and equity. CSLDC has
considered GFA addition of Rs. 0.09 Crore for 2021-22 as per Audited Accounts.

Commission’s View
The Commission has approved the closing GFA for FY 2020-21 as Rs. 16.38 Crore
after True-up in the Order dated April 13, 2022. The Commission has accordingly
considered the same amount as Opening GFA for FY 2021-22. As discussed in earlier
Chapter of this Order, the Commission notes that CSPTCL‟s audited accounts for FY
2021-22 reported the actual capitalisation of Rs. 134.83 Crore during the year, which
is entirely attributable to CSPTCL. For CSLDC, capitalisation in FY 2021-22 is Rs.
0.09 Crore, and the Commission has considered the same for FY 2021-22 based on

138 CSERC Tariff Order FY 2022-23


submission of CSLDC. Accordingly, the Commission approves the GFA and its
funding for FY 2021-22 as shown in the following Table:
Table 6-7: Gross Fixed Assets and its Funding for FY 2021-22 for CSLDC as
approved by the Commission (Rs. Crore)
Sr. No. Particulars Tariff Order Petition Approved
1 Opening GFA 16.38 16.38 16.38
2 Capitalisation during the Year 0.00 0.09 0.09
3 Closing GFA 16.38 16.47 16.47
Means of Finance
4 Consumer Contribution/Grants - - -
5 Equity 0.03 0.03
6 Debt 0.06 0.06
7 Total Capitalisation 0.00 0.09 0.09

6.6 Depreciation
CSLDC’s Submission
CLSDC submitted that it has computed depreciation as per Regulation 24 of CSERC
MYT Regulations, 2015. The asset base of CSLDC comprises SCADA system,
computer terminals, equipment, building, etc. The asset base has been identified from
the accounts of CSPTCL by the Asset Segregation Committee and the same has been
considered in its computations. As the asset class-wise segregation of the SLDC‟s
asset base is not available, the weighted average depreciation rate as considered for
CSPTCL for FY 2021-22 has been considered for CSLDC. CSLDC requested to
approve depreciation of Rs. 0.86 Crore for FY 2021-22.

Commission’s View
The Commission has approved the depreciation for FY 2021-22 in accordance with
the approach adopted in the past Orders. The closing GFA approved in the true up for
FY 2020-21, has been considered as the opening GFA for FY 2021-22. The GFA
addition for FY 2021-22 has been considered as approved in earlier Section of this
Chapter. The weighted average depreciation rate of 5.26%, computed for CSPTCL on
the basis of deprecation rates provided in the MYT Regulations, 2015, has been
considered for FY 2021-22 for CSLDC. The depreciation approved by the
Commission for FY 2021-22 is shown in the Table below:
Table 6-8: Depreciation for FY 2021-22 for CSLDC as approved by the
Commission (Rs. Crore)
Sr. Particulars Tariff Petition Approved
No. Order
1 Opening GFA 16.45 16.38 16.38
2 Additional capitalization during 2.01 0.09 0.09
the year
3 GFA at the end of the year 18.46 16.47 16.47
4 Average GFA for the year 17.45 16.42 16.43
5 Depreciation Rate 5.26% 5.26% 5.26%
6 Depreciation 0.92 0.86 0.86

CSERC Tariff Order FY 2022-23 139


6.7 Interest on Loan
CSLDC’s Submission
CSLDC has calculated Interest and Finance Charges as per Regulation 23 of the MYT
Regulations, 2015. CSLDC is not operating as a separate Company and, therefore, the
actual loan as applicable to CSPTCL has been considered. CSLDC has considered the
approved closing normative loan balance for FY 2020-21 as per the true-up Order, as
the opening normative loan balance for FY 2021-22. The debt component of 70% of
the GFA addition has been considered as the normative loan addition during the year.
The allowable depreciation for the year has been considered as the normative
repayment for the year. The rate of interest has been computed in accordance with
Regulation 23.5 of the MYT Regulations, 2015. The actual weighted average interest
rate of 9.97% for FY 2021-22 has been considered by CSLDC for computation of the
interest on loan. CSLDC requested to approve the Interest and Finance Charges of Rs.
0.12 Crore for FY 2021-22.

Commission’s View
The Commission has approved interest on loan capital for FY 2021-22 as per
Regulation 23 of the CSERC MYT Regulations, 2015. The Commission has
considered the closing net normative loan balance for FY 2020-21, as approved after
True-up, as the opening net normative loan balance for FY 2021-22. The addition of
normative loan has been considered based on debt component towards additional
capitalisation, as considered earlier in this Chapter. The repayment has been
considered equal to depreciation approved by the Commission in this Order.
Regulation 23.5 of the MYT Regulations, 2015 provides for the rate of interest based
on actual loan portfolio at the beginning of the year. For computation of weighted
average rate of interest, the Commission has considered the applicable rate of interest
on the outstanding loan portfolio of CSPTCL at the beginning of the financial year as
per the audited accounts of FY 2021-22, in absence of segregation of actual loan for
CSLDC. Accordingly, the Commission has considered the weighted average rate of
interest of 9.97% for FY 2021-22. The interest on loan approved for FY 2021-22 is
shown in the Table below:
Table 6-9: Interest on Loan for FY 2021-22 for CSLDC approved by
Commission (Rs. Crore)
Sr. Tariff
Particulars Petition Approved
No. Order
1 Total Opening Net Loan 1.67 1.62 1.62
2 Repayment during the period 0.92 0.86 0.86
3 Additional Capitalization of 1.41 0.06 0.063
Borrowed Loan during the year
4 Total Closing Net Loan 2.16 0.82 0.82
5 Average Loan during the year 1.91 1.22 1.22
6 Weighted Average Interest Rate 10.02% 9.97% 9.97%
7 Interest Expenses 0.19 0.12 0.12

140 CSERC Tariff Order FY 2022-23


6.8 Return on Equity (RoE) and Income Tax
CSLDC’s Submission
CSLDC has computed RoE as per the Regulation 22 of the MYT Regulations, 2015.
The closing permissible equity balance of FY 2020-21, as approved in the true-up
Order, has been considered as opening equity balance for true-up of FY 2021-22.
CSLDC has considered base rate of RoE of 15.50% (without grossing up by MAT
rate). CSLDC requested to approve RoE of Rs. 0.82 Crore for FY 2021-22.

Commission’s View
Regulation 22 of the CSERC MYT Regulations, 2015 provides that RoE shall be
computed by grossing up the base rate with the prevailing MAT rate of the base year
for projection purposes. The Commission notes that CSLDC has not paid any Income
Tax separately, hence, rate of return of RoE has not been grossed up with the
prevailing MAT rate. Accordingly, the Commission has approved RoE at rate of
15.50% as per Regulation 22 of the CSERC MYT Regulations, 2015.
For computation of RoE, the Commission has considered the closing equity as
approved for FY 2020-21 after True-up, as opening equity for FY 2021-22. The
equity addition for FY 2021-22 has been considered as 30% of the capitalisation
during the year. The Commission approves the RoE for FY 2021-22 as shown in the
Table below:
Table 6-10: Return on Equity for FY 2021-22 for CSLDC as approved by
Commission (Rs. Crore)
Sr. Tariff
Particulars Petition Approved
No. Order
1 Permissible Equity in Opening GFA 5.3 5.28 5.28
Addition of Permissible Equity
2
during the year 0.6 0.03 0.027
3 Permissible Equity in Closing GFA 5.9 5.31 5.31
Average Gross Permissible Equity
4
during the year 5.6 5.29 5.29
5 Rate of Return on Equity 15.50% 15.50% 15.50%
6 Return on Equity 0.87 0.82 0.82

6.9 Interest on Working Capital (IoWC)


CSLDC’s Submission
CSLDC has considered IoWC as per Regulation 25 of the CSERC MYT Regulations,
2015. CSPTCL submitted that it has considered one month of O&M expenses,
maintenance spares at 40% of R&M expenses, and receivables equivalent to one
month of revenue billed for computing the working capital requirement for FY 2021-
22. CSLDC has considered the interest rate of 10.90% (SBI Base Rate on 1st April
2021 @ 7.40% plus 350 basis points) for FY 2021-22 for computing the IoWC for FY
2021-22. CSLDC requested to approve IoWC of Rs. 0.35 Crore for FY 2021-22.

CSERC Tariff Order FY 2022-23 141


Commission’s View
The Commission has computed IoWC in accordance with Regulation 25 of the MYT
Regulations, 2015. It has been observed that CSLDC has considered actual R&M
expenses for calculation of Maintenance spares instead of normative R&M expenses.
For computation of working capital requirement as per the formula specified in the
CSERC MYT Regulations, 2015, the Commission has considered the revised
normative value of O&M expenses for FY 2021-22, as approved earlier in this Order.
The receivables have been considered based on the actual revenue of CSLDC during
FY 2021-22, as compared to CSLDC‟s approach of calculating the receivables from
the revenue required for FY 2021-22. The interest rate of 10.90% (7.40% + 3.5%) has
been considered for FY 2021-22, as per Regulation 25.4 of the MYT Regulations,
2015. The normative IoWC approved for FY 2021-22 is shown in the Table below:
Table 6-11: IoWC approved for FY 2021-22 for CSLDC by the Commission (Rs.
Crore)

Sr. Tariff CSLDC


Particulars Approved
No. Order Petition
1 O&M expenses for One Month 0.90 1.07 1.07
Maintenance Spares @ 40% of R&M 0.73 0.80 0.81
2
Expenses
3 Receivables @ 1 Month 1.24 1.37 1.54
4 Total Working Capital requirement 2.88 3.24 3.42
5 Rate of Interest on WC 10.90% 10.90% 10.90%
6 Net Interest on Working Capital 0.31 0.35 0.37

6.10 Non-Tariff Income


CSLDC’s Submission
CSLDC submitted that it has considered Non-Tariff Income (NTI) as Rs. 0.02 Crore
for FY 2021-22 based on the Segmental Notes to the Audited Accounts and requested
the Commission to approve the same.
Commission’s View
The Commission has considered NTI for CSLDC as per Segmental Notes of Audited
Accounts of FY 2021-22. Accordingly, the Commission considers NTI of Rs. 0.02
Crore for FY 2021-22.

6.11 Aggregate Revenue Requirement for CSLDC


Based on the above, the ARR approved for CSLDC after final truing-up for FY 2021-
22 is shown in the Table below:

142 CSERC Tariff Order FY 2022-23


Table 6-12: Aggregate Revenue Requirement (ARR) for FY 2021-22 approved
by the Commission (Rs. Crore)
Sr. Tariff Approved
Particulars Petition
No Order after True-up
1 Employee Expense 7.80 9.46 9.46
2 A&G Expenses 1.24 0.90 0.90
3 R&M Expenses 1.81 1.70 1.70
4 Terminal Benefits 1.80 1.80 1.80
5 Provision for Interim Wage Relief
Less: Capitalization of Employee,
6
R&M and A&G Expenses
7 Depreciation 0.92 0.86 0.86
8 Interest on Loan 0.19 0.12 0.12
9 Interest on Working Capital 0.31 0.35 0.37
10 Prior Period (Income)/ Expenses
11 Return on Equity 0.87 0.82 0.82
12 Gain/(Loss) on sharing O&M Expenses 0.40 0.39
13 Current Tax
14 Total 14.94 16.41 16.43
15 Less: Non-Tariff Income 0.02 0.02 0.02
Aggregate Revenue Requirement
16 14.93 16.39 16.41
(ARR)

6.12 Revenue from CSLDC Charges


CSLDC’s Submission
CSLDC submitted the revenue from CSLDC Charges of Rs. 14.90 Crore for FY
2021-22 based on the audited accounts.

Commission’s View
The Commission has considered the actual revenue from CSLDC Charges of Rs.
14.90 Crore in the true-up for FY 2021-22.

6.13 Revenue Gap/(Surplus) for CSLDC


CSLDC’s Submission
CSLDC submitted the Revenue Gap/(Surplus) for FY 2021-22, as shown in the Table
below:

CSERC Tariff Order FY 2022-23 143


Table 6-13: Revenue Gap/(Surplus) for FY 2021-22 as submitted by CSLDC
(Rs. Crore)
Sr. No. Particulars Amount
1 Aggregate Revenue Requirement 16.39
2 Less: Revenue from SLDC Charges 14.90
3 Standalone Revenue Gap/(Surplus) 1.49
4 Previous Gap 0.00
5 Total Revenue Gap/(Surplus) 1.49
CSLDC requested the Commission to approve the Gap of Rs. 1.49 Crore for FY
2021-22 and adjust Rs. 1.83 Crore (with carrying cost) in the ARR of FY 2023-24.

Commission’s View
After undertaking the final true-up for FY 2021-22, the Commission has computed
the Revenue Gap/(Surplus) for FY 2021-22, as shown in the following Table:
Table 6-14: Revenue Gap/(Surplus) for FY 2021-22 for CSLDC as approved by
the Commission (Rs. Crore)
Sr. No Particulars Petition Approved
1 Aggregate Revenue Requirement 16.39 16.41
2 Less: Revenue from SLDC Charges 14.90 14.90
3 Surplus/(Deficit) adjusted with carrying cost - 3.63
up to FY 2021-22 as approved in
Tariff Order dated 02.08.2021
4 Total Revenue for FY 2021-22 14.90 18.53
5 Revenue Gap/(Surplus) 1.49 (2.12)

The Commission approves the Revenue Surplus of Rs. 2.12 Crore after true-up
for CSLDC for FY 2021-22.

6.14 SLDC Charges for FY 2023-24


CSLDC’s Submission
CSLDC submitted that it has projected the annual SLDC Charges bifurcated into
System Operation Charges and Market Operation Charges function in accordance
with Regulation 102.2 of the CSERC MYT Regulations, 2021. In accordance with the
Regulation, 80% of the annual SLDC Charges determined above for FY 2023-24 have
been allocated to System Operation Charges, and 20% of the annual SLDC Charges
determined as above for FY 2023-24 have been allocated to intra-State Market
Operation Charges.
CSLDC has projected net ARR for FY 2023-24 as Rs. 18.93 Crore. CSLDC has
computed adjusted ARR for FY 2022-23 by considering net ARR of Rs. 18.93 Crore
and surplus arrived for FY 2020-21 along with holding cost of Rs. 3.34 Crore, as
discussed in the true up Chapter of this Order. Accordingly, CSLDC has requested the
Commission to approve total SLDC charges as Rs. 15.58 Crore, as shown in the Table
below:

144 CSERC Tariff Order FY 2022-23


Table 6-15: SLDC Charges claimed by CSLDC for FY 2023-24 (Rs. Crore)

Sr. No. Particulars FY 2023-24


1 ARR for FY 2023-24 as approved vide order dated
19.55
13.04.2022
2 Adjustment of Gap of FY 2021-22 after treatment of
1.83
carrying cost upto FY 2023-24
3 Adjusted ARR for FY 2023-24 21.38
4 System Operation Charges 17.11
5 Intra-State Market Operation Charges 4.28
6 Total SLDC Charges 21.38

Commission’s View
Regulation 102.2 of the MYT Regulations, 2021 specifies as under:
“102.2. Allocation and apportionment of components of annual charges to
system operation function and market operation function:
(a) Annual charges towards State system operation function shall
comprise 80% of the annual charges.
(b) Annual charges towards intra-State market operation function shall
comprise the balance 20% of annual charges.
(c) The ratio of allocation of annual charges to system operation charges
and market operation charges may be reviewed and decided by the
Commission from time to time."
The Commission in the final true up of FY 2021-22 has approved Surplus of Rs. 2.12
Crore. This Surplus along with holding cost, amounting to Rs. 2.55 Crore has been
adjusted against the ARR approved for FY 2023-24. Considering the adjusted ARR for
FY 2023-24 and above Regulation, the Commission has approved the System
Operation Charges and Intra-State Market Operation Charges, as shown in the Table
below:
Table 6-16: Adjusted ARR and SLDC Charges approved for FY 2023-24 (Rs. Crore)

Sr. Petitio Approve


Particulars
No. n d
ARR for FY 2023-24 as approved vide order dated 19.55 19.55
1
13.04.2022
Adjustment of Gap/(Surplus) of FY 2021-22 1.83 (2.55)
2
after treatment of carrying cost upto FY 2023-24
3 Adjusted ARR for FY 2023-24 21.38 17.00
4 System Operation Charges 17.11 13.60
5 Intra-State Market Operation Charges 4.28 3.40
6 Total SLDC Charges 21.38 17.00

CSERC Tariff Order FY 2022-23 145


7 REVIEW OF ORDER FOR FY 2022-23 FOR CSPDCL
7.1 Background
The Commission issued the Tariff Order on 13th April 2022 in Petition No. 75/2021,
wherein the Commission approved the final true up of FY 2020-21 and determined
the ARR for each year of the Control Period from FY 2022-23 to FY 2024-25 and
approved the retail supply tariff for FY 2022-23.
In the same order, the Commission also disposed of the Review Petition against Tariff
Order dated 02.08.2021.
CSPDCL submitted that they had filed a Review Petition against the order dated
02.08.2021 passed by the Commission in Petition No. 3 of 2020. The Commission has
directed the Petitioner to include the points of the review in the Tariff Petition for the
subsequent year. In accordance with the directions of the Commission, the Petitioner
has included the points raised in the Review Petition No. 54 of 2021 in the Tariff
Petition for the subsequent year.
CSPDCL has submitted that under review of order for FY 2021-22, the Commission
analysed power purchase expenses allowed to CSPDCL for FY 2018-19 and FY
2019-20, and on its own decided to deduct the expenditure of Rs. 488.69 Crore under
the head of “Other charges under Central Generating Stations (CGS)” being provision
for power banking in FY 2018-19 and also deducted Rs.154.67 Crore towards
provisioning of RPO/REC in FY 2019-20.
As regards the issue of deduction of Rs. 488.69 Crore in FY 2018-19, the
Commission has not considered the reversal entry of Rs. 388.54 Crore in FY 2019-20,
which is made in accounts to neutralize the unutilized provisions. Had this reversal
entry not been made in the accounts, the actual power purchase expenses towards
central generating stations would increase to Rs. 3846.33 Crore instead of audited
figures of Rs. 3457.73 Crore.
The aforesaid deduction has ignored the standard accounting practice of making
provisions for the expenses, which are to be incurred during the year and thus,
increase the expenses during that year. However, the unutilized provisions are
reversed during the next year through a negative entry thereby reducing the expenses
in the year of reversal. Under standard practice, the expenses are claimed as per
audited accounts, which include the new provisions created during the year and
reversal of the unutilized provisions during the previous year. Thus, the impact of
provisioning is considered on a net basis. Mere consideration of deducting Rs. 488.69
Crore in FY 2018-19 (as provisioning for expenses) without adding Rs. 388.54 Crore
in FY 2019-20 (negative entry to reverse unutilized provisions) has caused double
jeopardy to the petitioner.
Therefore, CSPDCL has filed this Review Petition to reconsider disallowance of
Rs.388.54 Crore in respect of provisioning of banking in power purchase expenses of
FY 2018-19.
All the issues raised by CSPDCL in its Review, along with all consequent
clarifications sought by the Commission, replies/clarifications submitted by CSPDCL,
and the Commission‟s analysis and ruling on all the issues have been addressed in this
Chapter.

146 CSERC Tariff Order FY 2022-23


7.2 Grounds for Review
CSPDCL’s Submission
CSPDCL submitted that the instant review petition is preferred against the impugned
order dated 13.04.2022 passed in Petition No. 75 of 2021, wherein the Commission
while truing up for FY 2020-21, has reopened the complete trued up parameters of FY
2018-19 and FY 2019-20 even when no review was preferred against such
parameters.
CSPDCL submitted that they had initially preferred a review petition against some
parameters in the Petition No. 03 of 2021 and that review petition was registered as
Petition No. 54 of 2021. Further, while deciding the review Petition, the Commission
had directed the Petitioner to include the details of such parameters in the tariff
determination petition for the subsequent years.
Further, CSPDCL has submitted that as per the directions of the Commission, the
Petitioner herein included the parameters for which it had filed review petition in the
tariff petition No. 75 of 2021. It is to be noted that the Petitioner had included those
parameters with respect to which it had filed review petition as the same was directed
by the Commission. However, the Commission while deciding the Petition No. 75 of
2021, which was for truing up of FY 2020-21, reviewed the already trued up figures
of FY 2018-19 and FY 2019-20 even when no prior order with respect to review of
such parameters was passed by the Commission.
CSPDCL has further added that the Commission has inadvertently erred by reopening
the trued-up tariff figure of the past years in the tariff determination petition for the
subsequent year due to which the Petitioner has suffered huge losses and therefore,
the instant review petition is filed.
Also the Commission while redetermining the trued-up figures of the past years in
Petition No. 75 of 2021 has committed accounting errors due to which Petitioner has
suffered losses amounting to Rs. 488.69 crore.

Commission’s View
The Commission has clearly laid out the basis on which the review of order in
Petition No. 75/2021 has been carried out. The relevant extracts are reproduced
below:

“The grounds for Review as per Regulation 23 of CSERC (Conduct of Business)


Regulations, 2009, are based on Order 47, Rule 1 of Code of Civil Procedure,
1908, i.e.:
 Error apparent on the face of the record;
 On submission of new and important evidence that was not in the knowledge
of the Petitioner at the time of the original Order;
 On account of any other sufficient reasons.
As stated above, the scope for Review of any Order is very limited, and the
Petitioner has to either prove a case of error apparent on the face of the record or
there should be new and important evidence that was not in the knowledge of the
Petitioner at the time of issue of original Order. However, considering the issues

CSERC Tariff Order FY 2022-23 147


raised by CSPDCL and the large impact of some of the issues on the concerned
years as well as future years, the Commission has adopted a holistic approach
rather than limiting itself to the narrow scope of Review, and has addressed each
issue raised by CSPDCL in its Review and the consequential issues, if any, on
merits, with the objective that CSPDCL should be able to recover all prudently
incurred expenses through the ARR and Tariff, even though the same may not
qualify within the narrow scope of a Review Petition.”
Hence, there is no merit in CSPDCL‟s contention that the Commission has exceeded
its jurisdiction in reviewing issues that were not raised by CSPDCL in its Review
Petition.
Further, this Review effectively amounts to seeking review of a Review Order, which
is not permissible. However, the Commission has adopted a holistic approach rather
than limiting itself to the narrow scope of Review, and has addressed the issue raised
by CSPDCL in its Review on merits, with the objective that CSPDCL should be able
to recover all prudently incurred expenses through the ARR and Tariff, even though
the same may not qualify within the narrow scope of a Review Petition.

7.3 Disallowance of provisioning of banking of Rs. 488.69 Crore in FY 2018-19


causing negative impact on power purchase expenses from Central Generating
Stations by Rs. 388.54 Crore during FY 2019-20
CSPDCL’s Submission
CSPDCL submitted that the Commission has dealt up with this issue at Para 6.11 of
impugned tariff order at page 174 to 176 and net impact at Table 6.16.
That decision to disallow Rs. 488.69 crore is based on fiction and imagination, which
reveals from the phrase “It could be included in the „Other charges‟ of Rs. 384.55
Crore claimed and allowed in the true up for FY 2019-20” and without taking into
consideration the audited accounts submitted in support with final true up as well as
Review Petition. Relevant observation in impugned tariff order as given below:
“It could be included in the „Other charges‟ of Rs. 384.55 crore claimed and
allowed in the true up for FY 19-20. Hence there is a credit amount of Rs. 100.16
crore which has been adjusted in the book of accounts of CSPDCL but which is
yet to be adjusted in the regulatory accounts. In this order, on revised true up of
FY 19-20, the Commission has not disallowed any expenses against provision for
banking, in the absence of real data in this regard”.
CSPDCL has submitted that the provisioning is an accounting process, wherein the
provisions are created for the foreseen expenses and the unutilised provisions are
reversed during the subsequent years. The Commission has disallowed the provisions
created in FY 2018-19 without considering the impact of reversal of these provisions
in FY 2019-20. The extracts of audited accounts (with GL entry) and constituents of
approved power purchase expenses demonstrate that effect of non-considering
reversal entry in account has caused disallowance of Rs. 388.54 Crore in expenditure
incurred in power purchase from Central Generating Stations (CGS) is shown in table
below:

148 CSERC Tariff Order FY 2022-23


Power Purchase Cost (in Rs. Crore) Disallowed
Source Audited Accounts Approved in final expenses as per
(with GL entry) true up audited accounts
4015.13
CGS 3626.59 388.54
(E170101)
5782.65
CSPGCL 5782.65 -
(E170102)
616.19
IEX/PXIL/TRAD 616.19 -
(E170104/108)
522.4
CPP/IPP/Short Term 522.40 -
(E170105)
274.57
Concessional Power 274.57 -
(E170104)
879.96
Others– Renewables 879.97 -
(E170106,107,110)
1368
Transmission Charges 1368 -
(E170201)
Other Miscellaneous 7.94
(7.94) -
Charges (E170208/214)
6.38
Border Villages 6.38 -
(E170103)
43.14
Net DSM Charges 43.14 -
(E170116)
Gross Power Purchase
13500.48 13111.95 388.54
Cost

CSPDCL submitted that disallowance of provisioning of power banking in FY 2018-


19 on one hand and allowing reversal entry to approve power purchase expenses in
FY 2019-20 on other hand is contradictory approach causing double jeopardy to the
petitioner. The observation that „In this order on revised true up for FY 2019-20, the
Commission has not allowed any expenses against provision for power banking, in
the absence of clear data‟ (page no. 176) is misconception as the petition was
supported by audited accounts as well as replies to additional queries raised in data
gaps.

Commission’s View
CSPDCL has claimed impact of Rs. 388.54 Crore under the Review. In the Order in
Petition No. 75 of 2021, the Commission has made the following observations:
a) It could be included in the „Other charges‟ of Rs. 384.55 crore claimed and
allowed in the true up for FY 2019-20.
b) Also, there is a credit amount of Rs. 100.16 crore, which has been adjusted in
the book of accounts of CSPDCL, but which is yet to be adjusted in the
regulatory accounts.
c) In this order, on revised true up of FY 2019-20, the Commission has not
disallowed any expenses against provision for banking, in the absence of real
data in this regard.

CSERC Tariff Order FY 2022-23 149


Accordingly, the Commission vide its data gaps asked CSPDCL to submit the details
of „Other Charges‟ of Rs. 384.55 Crore claimed in the true-up for FY 2019-20.
CSPDCL vide its reply dated 23rd January 2023, submitted its reply as under:
“CSPDCL humbly submits that actual Party wise details of the provision
made, and the reversals made during 2019-20 as shown under:
(Amount in Rs. Crore)
Particulars Credit Debit Net Balance
Being Provision for Power Purchase
0.05 0.05
made
Being provision for Power Purchase
395.89 395.89
made
Being reversal of opening provision
11.58 11.58
for Power Purchase made
Total 11.58 395.94 384.35

From the above reply submitted by CSPDCL, it is clear that the Commission’s
assessment that the amount claimed by CSPDCL could be included in the ‘Other
charges’ of Rs. 384.55 crore claimed and allowed in the true up for FY 2019-20,
were absolutely correct. The amount of Rs. 384.35 Crore in the above Table is
clearly provisioning for power purchase expenses, which has been allowed by the
Commission, in the absence of data, though the Commission’s philosophy that
expenses merely provided for should not be allowed in the regulatory accounts.
Further, the Commission has also not adjusted the credit amount of Rs. 100.16
crore in the true-up for FY 2019-20, again due to the lack of data.
Thus, the amount already allowed to CSPDCL is much higher than the amount
claimed by CSPDCL in its Review Petition. CSPDCL is directed to adjust the
balance provisioning in the future Petitions, and ensure that it does not claim any
amount merely provided for in the Accounts.

150 CSERC Tariff Order FY 2022-23


8 TRUE-UP OF FY 2021-22 FOR CSPDCL
8.1 Background
CSPDCL has filed the Petition for final True-up of FY 2021-22 based on the Audited
Accounts in accordance with Regulations 10.2 and 10.3 of the CSERC MYT
Regulations, 2015, which provides as under:
“10.2 .................The Distribution Licensee shall file an application for
truing up of the previous year(s) and determination of tariff for the
ensuing year, within the time limit specified in these Regulations.
… ….
10.3. In case the audited accounts are not available, the provisional
truing up shall be done on the basis of un-audited/ provisional account
and shall be subject to further final truing up, as soon as the audited
accounts is available.”
CSPDCL submitted that the revenue impact of the issues raised in the review of the
Tariff Order dated April 13, 2022 have also been included in the true up gap of FY
2021-22.
In accordance with the above, the Commission has undertaken the final true-up for
FY 2021-22. In this Chapter, the Commission has analysed all the elements of audited
expenditure and revenue of CSPDCL for FY 2021-22 and undertaken final true-up of
expenses and revenue in accordance with Regulation 10 of the MYT Regulations,
2015.
The Commission has approved the sharing of gains and losses on account of
controllable factors between CSPDCL and the consumers, in accordance with
Regulation 13 of the MYT Regulations, 2015.

8.2 Energy Sales


CSPDCL’s Submission
CSPDCL submitted that there were 60,23,795 consumers at LV level and 3,356
consumers at HV and EHV level during FY 2021-22. The Commission in the MYT
Order had merged HV and EHV categories into supply at HV level effective from 1st
April 2016. CSPDCL submitted that the connected load recorded during FY 2021-22
was 6,908.31 MW at LV level and 3,393.50 MW at EHV and HV level.
The category-wise energy sales were recorded as 25,161.29 MU for FY 2021-22,
comprising 14,349.96 MU sales to LT consumers and 10,811.33 MU to HV and EHV
consumers.

Commission’s View
The Commission sought actual category-wise and slab-wise sales in kWh for all LV
consumers and category-wise sales in kVAh for all HV consumers for FY 2021-22.
The Commission also sought voltage-wise break up for HV and EHV sales for FY
2021-22. CSPDCL submitted the R-15 data for FY 2021-22.

CSERC Tariff Order FY 2022-23 151


Agriculture Consumption
The Commission sought explanation for the higher actual agricultural sales reported
by CSPDCL as compared to the approved sales. In its reply dated 23rd January 2023,
CSPDCL submitted that the Commission while approving the sales for FY 2021-22
has considered the actual sales from April 2020 to November 2020 and further this
category of consumers did not get significantly impacted by the lockdown on account
of Covid-19. Also, the actual numbers of metered consumers increased during FY
2021-22 as compared to the estimated number of consumers during FY 2019-20. The
relevant details of number of consumers along with consumption is shown in the table
below:
Sl. Month FY 2021-22 (Actuals)
No. No. of MU Sold
Consumer
1 April 2021 461572 482.61
2 May 2021 462703 307.70
3 June 2021 465116 303.59
4 July 2021 468569 434.85
5 August 2021 471819 517.91
6 September 2021 475669 377.73
7 October 2021 477284 399.74
8 November 2021 479569 272.59
9 December 2021 481771 336.79
10 January 2021 484460 374.48
11 February 2021 486116 456.26
12 March 2021 489664 556.02
YEAR 2021-22 489664 4820.29
Actual 2020-21 459686 4938.63

CSPDCL further submitted that as per past performance of CSPDCL during FY 2020-
21, it had sold 4938.63 MU to LV 3 category, which signifies that the sales to LV 3
category in FY 2021-22 is on lower side as compared to the actual sales in
FY 2020-21.
CSPDCL further submitted month-wise average hours of supply to agriculture
category, which shows average supply approximately of 18 hours/day for each month
of FY 2021-22.
The Commission also sought details of load factor of consumption by LV Agriculture
category. In response, CSPDCL submitted the details of month-wise load factor for
FY 2021-22. It is observed that actual average annual load factor recorded was
45.25% for FY 2021-22, which translates to average running of 11 hours per day
throughout the year. Further examination reveals that in some months, the actual load
factor has been reported much higher, at 61.67% for March 2022 and 58.83%,
56.46%, and 49.51% for August 2021, April 2021, and July 2021, respectively. This
translates to average running hours of 12 hours in July 2021, ~ 14 hours in April and
August 2021, and as high as ~15 hours in March 2022. Such data lacks credibility and
CSPDCL is directed to ensure that the agricultural connections are metered

152 CSERC Tariff Order FY 2022-23


properly and meters read on time, so that the agricultural consumption is
reported realistically and correctly.
Regulation 11.1 of the CSERC MYT Regulations, 2015 provides that the sales mix
and quantum of sales are uncontrollable factors. The Commission therefore, approves
the energy sales as submitted by CSPDCL in its Petition for final True-up of FY
2021-22.
The consumer category-wise sales for FY 2021-22 approved in the Tariff Order,
actual sales as submitted by CSPDCL, and Trued-up sales approved in this Order are
shown in the Table below:
Table 8-1: Approved Energy Sales for FY 2021-22 (MU)

Tariff Final
Consumer Category Petition
Order True-up
LV Categories (A) 13,917.83 14,349.96 14,349.96
Domestic Including BPL Consumers 6,595.60 6,223.74 6,223.74
Non-Domestic (Normal Tariff) 266.20 266.20
927.52
Non-Domestic (Demand Based) 741.51 741.51
Agriculture Metered 4,408.13 4,820.29 4,820.29
Agriculture allied 25.69 31.03 31.03
LT Industry 564.89 672.63 672.63
Public Utilities 442.18 466.06 466.06
IT Industry 0.08 1.20 1.20
Temporary 953.74 1,127.31 1,127.31
HV Categories (B) 11,283.82 10,811.33 10,811.33
Railway Traction 1,085.30 1,159.65 1,159.65
Mines (Coal & Others) 737.32 682.98 682.98
Other Industry & General Purpose Non-
1,915.81 1,879.09 1,879.09
Industrial
Steel Industries 7,173.41 6,691.62 6,691.62
PWW, Irrigation & Agriculture allied
185.04 191.27
activities 191.27
Residential Purpose 171.68 177.91 177.91
Start-up Power Tariff 12.39 18.64 18.64
Industries related to manufacturing of
2.39 2.92 2.92
equipment for RE power generation
IT Industries 0.48 7.24 7.24
Temporary - - -
Grand Total (A+B) 25,201.65 25,161.29 25,161.29

CSERC Tariff Order FY 2022-23 153


8.3 Distribution Loss and Energy Balance
CSPDCL’s Submission
CSPDCL submitted that the energy losses for 33 kV and below system has been
computed based on Regulation 71.1 and 71.2 of the CSERC MYT Regulations, 2015,
as reproduced below:
71.1 “The energy loss for 33 kV and below voltage level, shall be evaluated
taking into consideration the clause 4.2.5 and 8.4.3 of the State Grid Code
2011. The difference between the energy injected at 33 kV voltage level and
the sum of energy sold to all consumers (retail and open access), at voltage
level 33 kV and below shall be the energy loss for the 33 kV and below
system. The same shall be considered for gain/loss at the time of true up.

71.2. Energy sold shall be the sum of the metered sales and assessed
unmetered sales, if any, based on prudence check by the Commission.”
In view of the above said provisions, CSPDCL has submitted the Distribution Loss
and Energy Balance for FY 2021-22, as shown in the Table below:
Table 8-2: Energy Balance for FY 2021-22 as submitted by CSPDCL (MU)
Sl. Particulars Tariff Order Petition
1 LV Sales 13,917.82 14,349.96
2 HV Sales 8,007.10 7,019.36
3 Total Sales below EHV Level 21,924.92 21,369.32
4 Distribution Loss below 33 kV (in %) 16.00% 18.48%
5 Distribution Loss below 33 kV (in MU) 4,176.18 4,842.97
6 Gross Energy requirement at 33 kV Level 26,101.10 26,212.29
7 Less: Direct Input to distribution at 33 kV Level 150.75 305.92
8 Net Energy Input required at Distribution
25,950.35 25,906.37
Periphery at 33 kV Level
9 Sales to EHV consumers 3,276.73 3,791.97
10 Net energy requirement at Distribution periphery 29,227.08 29,698.34
11 Distribution loss including EHV Sales 14.22% 16.14%

Commission’s View
In the Tariff Order for FY 2021-22, the Commission had directed CSPDCL to submit
the energy input/output duly certified by CSLDC for the year for which True-up is
being sought along with the next Tariff Petition. However, CSPDCL has not
submitted such certification from CSLDC. For the purpose of true-up for FY 2021-22,
the Commission has accepted the energy input as submitted by CSPDCL, after
applying due prudence check on the data submitted by CSPTCL.

154 CSERC Tariff Order FY 2022-23


The Commission has considered the Energy Balance based on the actual Inter-State as
well as Intra-State Transmission losses, energy sales approved in this order and actual
quantum of power procured during FY 2021-22.
The Commission has approved the Energy Balance as per the provisions of CSERC
MYT Regulations, 2015 and methodology adopted in previous Tariff Orders. The
approved Distribution Losses and Energy Balance after final true-up for FY 2021-22,
in the format adopted in the previous Tariff Order, is shown in the Table below:
Table 8-3: Approved Energy Balance and Distribution Loss for FY 2021-22

Tariff Final
Sl. Particulars Petition
Order True-up
A Input: Total Energy available (MU) 29,377.83 30,004.26 30,004.26
i. Available at 33 kV outgoing feeder 25,950.35 25,906.37 25,906.37
ii. Injected by CPP/IPP at 33/11kV S/s 150.75 305.92 305.92
iii. Available a EHV Level 3276.73 3791.97 3791.97
B Output: Total Energy Sales (MU) 25,201.65 25,161.29 25,161.27
i. LV Sales 13,917.82 14,349.96 14,349.96
ii. HV Sales 8,007.10 7,019.36 7,016.21
iii. EHV Sales 3276.73 3,791.97 3,795.11
Energy Loss below 33 kV (MU) {(Ai + Aii)
C 4,176.18 4,842.97 4846.12
– (Bi +Bii)}
Energy Loss below 33 kV (%)
D 16.00% 18.48% 18.49%
{C/(Ai+Aii)*100}
Distribution Loss Including EHV Sales
E 4176.18 4842.97 4842.99
(MU) (A – B)
Distribution loss including EHV Sales
F 14.22% 16.14% 16.14%
(E/A*100)

8.4 Incentive/Disallowance for over/under-achievement of distribution loss


CSPDCL’s Submission
CSPDCL submitted that the Distribution Loss approved vide Commission‟s Order
dated 2.8.2021 for FY 2021-22 is 16%. However, as per the MoU signed under Ujwal
DISCOM Assurance Yojana (UDAY) Scheme, the Distribution Loss target for FY
2018-19 onwards for CSPDCL was 15%. These targets were however, flexible in
nature and the relevant clause of the MoU states that:
“However, if the target in particular year is not met, then the CSPDCL shall strive
to achieve the targets in subsequent years so as to achieve the desired target”
CSPDCL submitted that in consideration of the revised targets set by the Commission
due to signing of UDAY MoU, CSPDCL has computed the under-achievement,
which demonstrates a deduction of Rs. 131.50 Crore from the ARR, as shown in the
Table below:

CSERC Tariff Order FY 2022-23 155


Table 8-4: Sharing of Loss on account of underachievement of Distribution loss
for FY 2021-22 as submitted by CSPDCL (Rs. Crore)
Sl. Particulars Legend Petition
Energy Input considered for Distribution
1 A 29,698.34
Business (MU)
2 Total Sales (MU) B 25,161.29
3 Power Purchase Cost (Rs. Crore) C 16,112.50
4 Gross Power Purchase Quantum (MU) D 37,692.29
Power Purchase Cost excluding Transmission
5 E 14,180.59
Charges (Rs. Crore)
6 Power Sales to Marwah quantum (MU) F 1,631.25
7 Less: Power Sale of Marwah (Rs. Crore) G 699.36
Net Power Purchase Cost for Loss Sharing (Rs.
8 H=E-G 13,481.24
Crore)
9 Per Unit Cost of Power Purchase (Rs/kWh) I = H/D*10 3.58
10 Targeted Distribution Losses (%) J 16.00%
11 Actual Distribution Losses (%) K 18.48%
12 Under achievement (%) L=K–J 2.48%
13 MU Shortfall M = L*A 735.31
N=(M*I*
14 Loss Due to Under-achievement (Rs. Crore) 263.00
1000)/100
15 CSPDCL Share (Rs. Crore) O = N/2 131.50

CSPDCL further submitted that as the target revisions due to UDAY MoU did not
involve any material revision to the capital investment plan, which is necessary for
reduction of distribution losses, hence, CSPDCL has not considered the aforesaid
under-achievement in its ARR. Further, the Commission in the backdrop of no
revision in capital investment plan, may evaluate under-achievement on the basis of
pre-revised targets. CSPDCL submitted that the Commission has powers to relax the
aforesaid provisions in accordance with Regulation 83 of the MYT Regulations, 2015.

Commission’s View
As regards the target Distribution Losses, the CSERC MYT Regulations, 2015
specified as under:
“71.3. Energy Loss trajectory for 33 KV and below system for State utility for
each year of the control period shall be as under
FY 2016-17 - 22.0%
FY 2017-18 - 21.0%
FY 2018-19 - 20.0%

156 CSERC Tariff Order FY 2022-23


FY 2019-20 - 19.0%
FY 2020-21 - 18.0%
For other distribution licensees, the trajectory shall be given in the respective
tariff order.”
However, in the first Amendment to the CSERC MYT Regulations, 2015 notified on
16th June 2017, the following proviso was added in Regulation 71.3:
“Provided that if the State utility enters into any agreement with Government of
India and/or Chhattisgarh Government and energy loss trajectory committed in
this agreement is contrary to that as specified in this Regulations, the energy
loss trajectory agreed under the agreement shall prevail over the energy loss
specified in this Regulations.”
CSPDCL has signed a “Tripartite Memorandum of Understanding” with Ministry of
Power (Government of India) and Government of Chhattisgarh under UDAY on 25th
January 2016 to achieve financial turnaround. The targets specified under UDAY are
as follows:
“1.3 (c) The CSPDCL shall endeavour to reduce AT&C Losses from 22.50% in
the FY 2014-15 to 15% by FY 2018-19 as per the following trajectory:

Year FY 2015-16 FY 2017-18 FY 2017-18 FY 2018-19


AT&C losses 21.00 18.93 18.00 15.00

However, if the target in particular year is not met, then the CSPDCL shall
strive to achieve the targets in subsequent years so as to achieve the desired
target of 15% AT&C losses by the FY 2018-19.”(emphasis added)
In the Tariff Order for FY 2019-20, the Commission has already decided the issue
regarding target of Distribution Losses as per UDAY Scheme. The relevant extract of
the Order is reproduced below:
“CSPDCL has submitted that the tripartite MoU signed between GoI, GoCG and
CSPDCL should not be considered as an agreement and hence cannot supersede
the Distribution Loss trajectory specified in MYT Regulations, 2015. In this
regard, the Commission notes that the prevailing Loss trajectory specified in the
MYT Regulations, 2015 (Regulation 71.3) was amended on June 16, 2017,
providing for adoption of any subsequent trajectory agreed upon between
CSPDCL on one hand and State and/or Central Government on the other. The
Amendment is reproduced below:
“Provided that if the State utility enters into any agreement with Government of
India and/or Chhattisgarh Government and energy loss trajectory committed in
this agreement is contrary to that as specified in this Regulations, the energy loss
trajectory agreed under the agreement shall prevail over the energy loss specified
in this Regulations.”
UDAY scheme is intended to turn-around the financial health of the Distribution
companies, reeling under huge debt burden, which was ultimately passed to the
consumers through tariff. The loss reduction trajectory, as envisaged in the
Scheme was in fact agreed to by the parties after negotiations, and is an essential
component towards achieving the objective of MoU. Further, it needs to be

CSERC Tariff Order FY 2022-23 157


stressed here that there is no practice of executing agreements amongst
governments and government agencies; instead, MoU is the general practice and
in pursuance of the same, GoCG has fulfilled its commitment towards conversion
of 50 % of CSPDCL's total debt (Rs. 870.12 cr.) into grants. One has to
appreciate that the Regulations were amended to facilitate implementation of
such schemes and reforms. Therefore, Commission is of the view that one has to
go by the intent and spirit behind the tripartite Understanding and the amended
Regulations and not get bogged down with the mere wordings. Accordingly,
CSPDCL has to honour its commitment towards reduction in distribution loss to
the agreed level. Thus, the Commission approves the Distribution Loss Target for
FY 2016-17 and FY 2017-18, as per UDAY MoU.”
The Distribution Loss target below 33 kV approved by the Commission in the Tariff
Order for FY 2021-22 based on the UDAY scheme, is 16.00%. The actual
Distribution Loss below 33 kV achieved by CSPDCL during FY 2021-22 as
submitted by CSPDCL and as computed by the Commission based on actual energy
sales and power purchase, works out to 18.49%. Thus, CSPDCL has reported higher
Distribution Loss for FY 2021-22, as compared to the targeted Distribution Loss.
The CSERC MYT Regulations, 2015 specifies as under, as regards sharing of
efficiency losses on account of under-achievement of Distribution Losses:
“13.2. The mechanism for sharing of aggregate net loss on account of under
achievement in reference to the target set in tariff order for efficiency linked
controllable items shall be passed on to the beneficiary / consumer(s) and
retained by the generating company or the licensee, as the case may be, in the
ratio of 50:50 or as may be specified in the Order of the Commission passed
under these Regulations.”
Further, while computing the efficiency loss on account of higher than approved
Distribution Losses, CSPDCL has excluded the Transmission Charges and quantum
and cost of purchase from Marwah station of CSPGCL. As elaborated in the previous
Tariff Order, the Transmission Charges should be excluded while computing the
average cost of power purchase for the purpose of computing efficiency gains/losses
on account of Distribution Losses, however, the quantum and cost of purchase from
Marwah station of CSPGCL cannot be excluded.
In response to the Commission‟s query in this regard, CSPDCL has submitted the
revised computation of sharing of loss without deduction of power purchase cost from
Marwah as shown below:
Table 8-5: Revised Sharing of Loss on account of underachievement of Distribution loss for FY
2021-22 as submitted by CSPDCL (Rs. Crore)
Sl. Particulars Legend Petition
Energy Input considered for Distribution Business
1 A 29,698.34
(MU)
2 Total Sales (MU) B 25,161.29
3 Power Purchase Cost (Rs. Crore) C 16,112.50
4 Gross Power Purchase Quantum (MU) D 37,692.29
Power Purchase Cost excluding Transmission
5 E 14,180.59
Charges (Rs. Crore)
8 Net Power Purchase Cost for Loss Sharing (Rs. H 14,180.59

158 CSERC Tariff Order FY 2022-23


Sl. Particulars Legend Petition
Crore)
9 Per Unit Cost of Power Purchase (Rs/kWh) I = H/D*10 3.76
10 Targeted Distribution Losses (%) J 16.00%
11 Actual Distribution Losses (%) K 18.48%
12 Under achievement (%) L=K–J 2.48%
13 MU Shortfall M = L*A 735.31
N=(M*I*
14 Loss Due to Under-achievement (Rs. Crore) 276.64
1000)/100
15 CSPDCL Share (Rs. Crore) O = N/2 138.32

The Commission has assessed the impact of under-achievement of Distribution Loss


vis-à-vis the targeted Distribution Loss, and shared 50% of the efficiency losses on
account of under-achievement of Distribution Losses, as shown in the Table below:
Table 8-6: Sharing of Loss approved by the Commission on account of
underachievement of Distribution loss for FY 2021-22 (Rs. Crore)
Final
Sl. Particulars
True-up
1 Energy recorded at 33 kV Outgoing feeder of all EHV S/s (MU) 25,906.37
2 Add: Net Energy injected generators connected at 33/11 kV S/s (MU) 305.92
3 Add: Available at EHV level (MU) 3791.97
4 Energy Input considered for Distribution Business (MU) 30,004.26
5 Distribution Losses (%) below 33 kV Level 18.49%
6 Targeted Distribution Losses (%) 16.00%
7 (Over)/Under achievement (%) 2.49%
Total Power Purchase Cost excluding Transmission Charges (Rs.
8 13,852.30
Crore)
9 Power Purchase Quantum (MU) 37,688.87
Average Power Purchase Cost at Distribution Periphery (Incl. EHV)
9 3.68
(Rs/kWh)
10 Under-achievement amount 274.37
11 Under-achievement to be borne by CSPDCL 137.19

The above impact of under-achievement to be borne by CSPDCL has been adjusted


against the ARR of CSPDCL for FY 2021-22.

8.5 Power Purchase Cost


CSPDCL’s Submission
CSPDCL has purchased power from different sources such as Central Generating
Stations (CGS), CSPGCL generating stations, Renewable Energy (RE) sources such
as Bio-mass, Solar, Wind and other RE sources, Concessional power from
Independent Power Producers (IPPs) through Chhattisgarh State Power Trading

CSERC Tariff Order FY 2022-23 159


Company Limited (CSPTrDCL) and other sources such as Power Exchanges, etc., to
meet the energy requirement of the State during FY 2021-22.
CSPDCL submitted that the gross power purchase cost as per final audited accounts is
Rs.16,112.50 Crore for purchase of 37,692.29 MU, i.e., average cost per unit of Rs.
4.27/kWh, which includes Transmission Charges of Rs. 1931.91 Crore. CSPDCL
further submitted that it has purchased 308.67 MU through banking arrangement and
has sold 718.68 MU through banking arrangement, with the cost of both the
transactions being considered as NIL, in line with the Judgment of Hon‟ble APTEL
dated 1st July 2014 in Appeal No. 220 of 2013. CSPDCL also submitted that the
Delayed Payment Charges (DPC) billed by CSPGCL, CGS Stations and Transmission
Utilities has not been included in the power purchase cost claimed by CSPDCL.
CSPDCL has considered the revenue from sale of surplus power to Telangana and
others as Rs. 1854.14 Crore. The net power purchase cost claimed by CSPDCL for
purchase of 31,730.02 MU for FY 2021-22 is Rs. 14258.36 Crore, resulting in
average cost per unit of Rs. 4.49/kWh, including the Transmission Charges.

Commission’s View
The Commission has scrutinized the available records including the power purchase
cost reflecting in the audited accounts of FY 2021-22, and the actual source-wise
power purchase cost for FY 2021-22 as submitted by CSPDCL in its Petition and
replies to queries.
CSPDCL has purchased power from CSPGCL Stations, CGS Stations, RE Sources,
and Short-Term sources. CSPDCL has claimed gross power purchase cost of
Rs.16,112.50 Crore for purchase of 37,692.29 MU, i.e., average cost per unit of Rs.
4.27/kWh, including Transmission Charges of Rs. 1931.91 Crore. CSPDCL has
submitted that it has only considered the forward Banking and return Banking units
and no cost has been considered against these units, in accordance with the related
APTEL Judgment.
CSPDCL has claimed net power purchase cost of Rs. 14,258.36 Crore for purchase of
31,730.02 MU for FY 2021-22 at an average cost of Rs. 4.49/kWh, including the
Transmission Charges, and after netting off the revenue from sale of surplus power.
The Commission has analysed the source-wise power purchase quantum and costs
and approved the same after prudence check in the final truing up for FY 2021-22, as
discussed in the paragraphs below.

CSPGCL Stations
CSPDCL has claimed purchase of 16,416.06 MU at a cost of Rs. 5,892.84 Crore from
CSPGCL Stations. However, the Commission has considered the cost as CSPGCL
actual revenue, which is Rs. 5,602.35 Crore, at an average cost of Rs. 3.41/kWh.
The Commission has hence, approved power purchase of 16,416.06 MU at a total
cost of Rs. 5,602.35 Crore from CSPGCL stations for FY 2021-22.
Central Generating Stations (CGS)
CSPDCL has claimed purchase of 15,429.44 MU at a cost of Rs. 6,029.59 Crore from
CGS Stations. The Commission has verified these expenses from the Audited
Accounts.

160 CSERC Tariff Order FY 2022-23


The Commission asked CSPDCL to submit the details and the Commission has
considered the cost as Rs. 6022.56 Crore as per reply dated January 23, 2023 by
CSPDCL, after reducing the DPC of Rs. 0.40 Crore of NTPC.
The Commission asked CSPDCL to submit the details of „Other Charges‟ of Rs. 279
Crore claimed by CSPDCL under CGS Power Purchase. Vide its reply dated 23 rd
January 2023, CSPDCL submitted the details of the „Other Charges‟, as under:
Table 8-7: Details of ‘Other Charges’ under CGS Power Purchase for
FY 2021-22 (Rs. Crore)
Sl. Details Quantum (MU) Cost Rate
(Rs. Crore) (Rs./kWh)
1 OHPCL 16.44 2.96 1.80
2 NHPCL 445.70 191.14 4.29
3 NEEPCO 55.01 22.04 4.01
4 Bundled Thermal Power 168.00 62.70 3.73
Total 685.15 278.84 4.07

The power purchase quantum and cost against other CGS sources, viz., NTPC,
NTPC-SAIL, NPCIL and OHPCL, NHPCL, NEEPCO, etc., have been considered as
submitted by CSPDCL in its reply dated 23rd January 2023.
The Commission has accordingly approved the quantum and cost of power
purchase from CGS for FY 2021-22 as 15,429.44 MU at the cost of Rs. 6,022.56
Crore in the true-up for FY 2021-22.

Renewable Energy Sources


The Commission has scrutinised the source-wise details of RE purchase during FY
2021-22. The Commission has verified the rates of power purchase based on tariffs
approved by the Commission in the past.
The Commission sought confirmation from CSPDCL regarding whether expense
against provisioning for RE power or RPO has been claimed in the true-up for FY
2021-22. In reply, CSPDCL submitted that no provision has been made for RE or
RPO during FY 2021-22 in the books of accounts.
The Commission has approved the quantum and cost of purchase from RE sources,
viz., Biomass, Solar, and Hydel/Other RE as submitted by CSPDCL, after verification
from the Audited Accounts of FY 2021-22.
The Commission has accordingly approved the quantum and cost of power
purchase from RE Sources for FY 2021-22 as 2,339.04 MU at the cost of Rs.
1,348.95 Crore in the true-up for FY 2021-22.

Power Purchase from CSPTrdCL (Concessional Power)


It is observed that CSPDCL has purchased 2,185.62 MU at the cost of Rs. 492.83
Crore during FY 2021-22 at an average rate of Rs. 2.25/kWh.

CSERC Tariff Order FY 2022-23 161


The commission has asked CSPDCL to submit the source-wise quantum and rate of
power purchase from „Concessional Power through CSPTrdCL‟ to which CSPTCL
has submitted the breakup as below:
S. Concessional Power through Quantum Amount (Rs. Rate (Rs.
No. CSPTrdCL in FY 2021-22 (MU) In Crore) /kWh)
1 M/s ACB (India) Ltd. (270 MW) 47.69 7.63 1.60
2 M/s ACB (India) Ltd. (50 MW) 0.14 0.02 1.60
3 M/s Spectrum Coal & Power Ltd. (Unit-I
11.92 1.91 1.60
& Unit-II)
4 M/s Jindal Power Ltd. 443.35 68.45 1.54
5 M/s ACB (India) Ltd. (30 MW) 2.35 0.38 1.60
6 M/s Korba West Power Company Ltd.
166.61 26.66 1.60
(REGL)
7 M/s Sai Lilagar Power Generation Ltd.
111.72 17.88 1.60
(Formally known as M/s ACPCL)
8 M/s DB Power Ltd. 268.13 86.58 3.23
9 M/s Balco 257.98 45.68 1.77
10 M/s Maruti Clean Coal & Power Ltd. 41.05 6.57 1.60
11 M/s Lanco Amarkantak Power Ltd. 90.05 17.78 1.97
12 M/s TRN Energy Pvt. Ltd 14.83 2.37 1.60
13 M/s KSK Mahanadi 315.90 50.54 1.60
Rebate (0.92)
14 M/s S K S Power Generation Ltd. 30.32 4.85 1.60
15 REL 383.58 61.37 1.60
(A) Total 2185.62 397.75 1.82
TCS 0.03
Additional Charges 95.16
TOTAL INCLUDING TCS 2185.62 492.93 2.25

The Commission has observed that CSPDCL has claimed “additional charges” of Rs.
95.16 Crore without any explanation, which the Commission has disallowed.
Thus, the Commission after due prudence check has considered the cost of Rs. 397.77
Crore at an average rate of Rs. 1.82/kWh towards purchase of Concessional Power
for FY 2021-22.

Other Sources
In the Petition, CSPDCL had submitted that during FY 2021-22, CSPDCL has
purchased 260.97 MU from short-term sources such as Traders and Power Exchanges
at a cost of Rs. 192.71 Crore at an average rate of Rs. 7.38/kWh. However, in its
replies to the data gaps, CSPDCL revised the cost to Rs. 230.62 Crore, at an average
rate of Rs. 8.84/kWh. The Commission, after due prudence check, has accepted the
total cost of short-term purchase of Rs. 230.62 Crore, as submitted by CSPDCL.

162 CSERC Tariff Order FY 2022-23


Unscheduled Power
In the Petition, CSPDCL had submitted that during FY 2021-22, CSPDCL has
received 337.78 MU of Unscheduled power at a rate of Rs. 1.65 /kWh, with total cost
of Rs. 55.82 Crore. However, in its replies to the data gaps, CSPDCL revised the cost
to Rs. 44.12 Crore, at an average rate of Rs. 1.31/kWh. The Commission, after due
prudence check, has accepted the total cost of Unscheduled power of Rs. 44.12 Crore,
as submitted by CSPDCL.

UI Purchase
In the Petition, CSPDCL had submitted that during FY 2021-22, CSPDCL has
purchased 411.73 MU under UI at a rate of Rs. 4.81/kWh, with total cost of Rs.
198.10 Crore. However, in its replies to the data gaps, CSPDCL revised the quantum
and cost to 409.74 MU and Rs. 216.57 Crore, at an average rate of Rs. 5.29/kWh. The
Commission, after due prudence check, has accepted the total quantum and cost of UI
power, as submitted by CSPDCL.

Banking Purchase and Sale


CSPDCL has submitted that it purchased 308.67 MU through banking arrangement
and sold 718.68 MU of banked power during FY 2021-22. CSPDCL has stated that it
has considered the cost of banking purchase and sale in FY 2021-22 as Nil, in
accordance with the Judgment of the Hon‟ble APTEL dated 1st July 2014 in Appeal
No. 220 of 2013.
The relevant extract of the Judgment is reproduced below:
“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.”
Though CSPDCL has been specifically claiming in all its Petitions that it has
considered the cost of banking purchase and sale as Nil in accordance with the above-
said Judgment of the Hon‟ble APTEL, the Commission has observed in the earlier
Chapter on Review of the Tariff Order for FY 2022-23 and in the previous Order that
CSPDCL has been including the provision made against such banked power quantum
every year in its Petitions. The Commission asked the petitioner to reconfirm whether
any expense has been claimed against banked power for FY 2021-22, to which the
CSERC Tariff Order FY 2022-23 163
Petitioner has replied that it has booked power banking income of Rs. 115.12 Crore.
The Commission has not considered the provisioning made by CSPDCL towards
power banking in FY 2021-22 under the power purchase cost. Further, the
Commission had given a directive to CSPDCL in the previous Order to submit details
and reconciliation of year-wise amount provisioned against Banked Power till date,
and actual amount spent/utilised against this provisioning till date. This data is to be
submitted along with the true-up Petition for each year, henceforth. Also, CSPDCL is
directed to ensure that all expenses towards return of banked power be fulfilled by
utilising the funds provisioned against Banked Power or any such similar
name/purpose till date, and ensure that such expenses are not claimed separately, till
such time as the entire provisioning amount is exhausted.
The Commission reiterates its direction that in future, CSPDCL shall not include the
expenses provisioned against banked power in its power purchase cost, and shall
consider the actual expenses incurred for the banking return, once the amount of
provisioning made till date is exhausted. CSPDCL shall submit a complete passbook
of forward banking and return banking showing all transactions in energy terms till
date, including the amount of expense provisioning done, expense provisioning set off
till date, and balance provisioning available for future set-off, along with the true-up
Petition for each year. In the absence of such complete data, the Commission may be
constrained to disallow a part of the power purchase expenses in future Orders.
In line with the regulatory principles, banking of power involves cashless transaction,
where interchange of units has to be accomplished. The Commission has considered
the quantum of banking purchase and sale as submitted in CSPDCL‟s Petition, in the
true-up for FY 2021-22.

Delayed Payment Charges


The Commission notes that the power purchase cost booked in the audited accounts of
CSPDCL for FY 2021-22 includes DPC of Rs. 277.51 Crore against CSPGCL as a
provision for surcharge.
CSPDCL submitted that it has not claimed the DPC booked in the Accounts of FY
2021-22 under the power purchase expenses in the true-up for FY 2021-22, which has
been verified by the Commission.
As per the approach adopted by the Commission in earlier Orders, both the income
and expense against DPC are not considered at the time of true-up. Hence, the
Commission has excluded the DPC of Rs. 277.51 Crore in the final true-up for FY
2021-22.

Reactive Charges and RRAS


CSPDCL has considered credit amount of Rs. (19.03 Crore) against RRAS settlement.
In reply to the Commission‟s query, CSPDCL submitted the break-up of the RRAS
settlement and stated that the credit amount has been adjusted against the gross power
purchase cost being a revenue receipt. The Commission has verified CSPDCL‟s claim
and considered the same in the true-up for FY 2021-22.

164 CSERC Tariff Order FY 2022-23


Transmission Charges
CSPDCL has claimed inter-State Transmission Charges of Rs. 957.53 Crore, intra-
State Transmission Charges of Rs. 962.50 Crore, and CSLDC Charges of Rs. 11.87
Crore, totalling to Transmission Charges of Rs. 1931.91 Crore.
In response to the Commission‟s query, CSPDCL submitted the break-up of inter-
State Transmission Charges in the same format as submitted in the Review for FY
2018-19 and FY 2019-20.
The Commission has scrutinized the Transmission Charges as submitted by CSPDCL
for FY 2021-22 in its true-up Petition and verified the same from the audited
Accounts of FY 2021-22. CSPTCL‟s claim of Transmission Charges tallies with the
amount booked in the Audited Accounts, excluding the DPC amount, which has not
been claimed by CSPDCL.
The Commission has allowed the inter-State Transmission Charges as claimed by
CSPDCL in its Petition. The intra-State Transmission Charges against CSPTCL have
been considered based on the revenue booked by CSPTCL for FY 2021-22, i.e., Rs.
967.64 Crore.
CSPDCL has claimed CSLDC Charges of Rs. 11.87 Crore for FY 2021-22, as against
CSLDC‟s claim of revenue of Rs. 14.90 Crore for FY 2021-22. The Commission has
approved the amount of Rs. 14.90 Crore as CSLDC Charges equal to the revenue
booked by CSLDC for FY 2021-22.
In view of the above, after due prudence check, the Commission approves the
Transmission Charges of Rs. 1,940.07 Crore for FY 2021-22.

Revenue from Sale of Surplus Power


CSPDCL has submitted the revenue from sale of surplus power for FY 2021-22. The
Commission has considered the revenue from sale of surplus power as submitted by
CSPDCL in its reply to the data gaps. However, the Commission has continued with
the methodology adopted in previous Orders by separate accounting of revenue from
sale of surplus power and revenue from retail-sale of power, and considering the
revenue from sale of surplus power under revenue rather than to reduce the gross
power purchase expenses. The revenue from sale of surplus power considered by the
Commission is shown in the Table below:
Table 8-8: Revenue from Sale of Power as approved by the Commission
Particulars MU Rs. Crore Rs/kWh
Sale of Surplus Power to Telangana 1631.25 699.36 4.29
Sale of Surplus Power to Power
3214.89 1125.45 3.50
Exchange
UI Sale 305.10 122.61 4.02
Banking Sale 718.68
Grand Total 5869.92 1947.42 3.32
The source-wise power purchase quantum and cost considered by the Commission after
final true-up for FY 2021-22, is shown in the Table below:

CSERC Tariff Order FY 2022-23 165


Table 8-9: Approved Power Purchase Cost after True-up for FY 2021-22 (Rs. Cr.)
Tariff Order Petition Final True-up
Source Quantum Cost Rate Quantum Cost Rate Quantum Cost Rate
(MU) (Rs. Cr.) (Rs./kWh) (MU) (Rs. Cr.) (Rs./kWh) (MU) (Rs. Cr.) (Rs./kWh)
Central Generating Stations 14,825.65 5,347.41 3.61 15,429.44 6,029.59 3.91 15,429.44 6022.56 3.90
NTPC 14236.4 5094.41 3.58 14,124.92 5,504.40 3.90 14,124.92 5504.93 3.90
NTPC-SAIL (NSPCL) 280.46 158.8 5.66 272.28 127.67 4.69 272.28 127.69 4.69
NPCIL 300.94 92.42 3.07 347.09 118.68 3.42 347.09 117.48 3.38
Others 7.85 1.78 2.27 685.15 278.84 4.07 685.15 272.46 3.98
Less: Rebate in AFC – COVID-19
Other Charges 0.00
CSPGCL 18,866.84 6,058.09 3.21 16,416.06 5,892.84 3.59 16,416.06 5602.35 3.41
Total CSPGCL Thermal & Hydro 18493.71 5994.01 3.24 16,384.26 5,881.42 3.59 16,384.26 5590.93 3.41
CSPGCL – Renewables 373.13 64.08 1.72 31.81 11.42 3.59 31.81 11.42 3.59
Short-term Purchase 124.49 41.93 3.37 260.97 192.7146 7.38 260.97 230.62 8.84
Concessional Power - through
1,530.87 244.94 1.60 2,185.62 492.83 2.25 2,185.62 397.77 1.82
CSPTrdCL
Others - Renewables 2,111.33 1,109.36 5.25 2,340.46 1,329.12 5.68 2,339.04 1348.95 5.77
Biomass 686.28 442.44 6.45 951.38 622.36 6.54 949.96 670.92 7.06
Solar 960.33 428.32 4.46 934.21 414.63 4.44 934.21 386.18 4.13
Hydel/Other RE 464.72 143.62 3.09 454.87 292.14 6.42 454.87 291.85 6.42
Solar and Non-solar RECs 94.98
Other Charges - RE
Transmission Charges 1644.6 1931.91 1940.07
Inter-State Transmission Charges 603.93 957.53 957.53
Intra-State Transmission Charges 1025.74 962.50 967.64

166 CSERC Tariff Order FY 2022-23


Tariff Order Petition Final True-up
Source Quantum Cost Rate Quantum Cost Rate Quantum Cost Rate
(MU) (Rs. Cr.) (Rs./kWh) (MU) (Rs. Cr.) (Rs./kWh) (MU) (Rs. Cr.) (Rs./kWh)
CSLDC Charges 14.93 11.87 14.90
Less: Rebate in AFC – COVID-19 0.00
Unscheduled Power 0 0 0 337.78 55.82 1.65 337.78 44.12 1.31
UI Purchase 0 0 0 411.73 198.10 4.81 409.74 216.57 5.28
Border Villages 0 0 0 1.56 1.46 9.34 1.56 1.24 7.96
Banking Purchase 0 0 0 308.67 308.67
Reactive Charges 0 0 0 7.15 7.15
RRAS Settlement (19.03) (19.03)
Gross Power Purchase Cost
37,459.18 12801.73 3.42 37688.87 13852.30 3.68
excluding Transmission Charges
Gross Power Purchase Cost
37,459.18 14,446.33 3.86 37,692.29 16,112.50 4.27 37688.87 15792.38 4.19
including Transmission Charges
Less: Adjustments 7,328.18 3,120.08 4.26 5,962.27 1,854.14 3.11 5869.92 1947.42 3.32
Sale to Telangana* 6349.58 2850.96 4.49 1,631.25 699.36 4.29 1,631.25 699.36 4.29
Sale of Surplus power to Power
978.6 269.12 2.75 3,214.89 1,126.57 3.50 3214.89 1125.45 3.50
Exchange*
UI Sales 397.45 28.22 0.71 305.10 122.61 4.02
Banking Sale 718.68 - 718.68
Net Power Purchase Cost 30,131.00 11,326.25 3.76 31,730.02 14,258.36 4.49 31818.95 13844.96 4.35
Note - *Sale of surplus power approved by the Commission is included in Revenue in subsequent Section of this Order

The Commission approves Gross Power Purchase Cost of Rs. 15,792.38 Crore and Net Power Purchase Cost of Rs. 13,844.96 Crore
after final Truing-up of FY 2021-22.

CSERC Tariff Order FY 2022-23 167


8.6 O&M Expenses
CSPDCL’s Submission
Based on audited accounts, CSPDCL submitted the O&M expenses of Rs. 1,396.31
Crore for FY 2021-22 excluding terminal benefits (pension and gratuity), as shown in
the Table below:
Table 8-10: Actual O&M expenses as submitted by CSPDCL (Rs. Cr.)
Sl. No. Particulars Tariff Order Petition
1 Employee Costs 947.51 848.85
2 A&G Expenses 145.26 157.41
3 R&M Expenses 135.00 390.04
4 Total O&M Expenses 1,227.78 1,396.31

CSPDCL requested the Commission to approve actual employee expenses of Rs.


848.85 Crore for FY 2021-22 based on the Audited Accounts.
CSPDCL submitted that the major services involved in distribution business, such as,
engagement of contract labour for operations of 33/11 kV Substations, meter reading,
bill distribution and revenue collection, secretarial assistance in offices, housekeeping
and security guards are performed through outsourcing, because a substantial strength
of sanctioned posts in Class III and IV cadre are vacant, and expenditure for engaging
outsourcing agencies are booked under the head of A&G expenses and R&M
Expenses. If the services provided by outsourcing agencies are to be performed
through regular appointments, then all such expenditures would qualify under
employee expenses at higher cost. Hence, it is in the interest of consumers that these
parts of the distribution business are performed by CSPDCL at a marginal low cost.
The details of such expenses incurred are given in the Table below:
Table 8-11: Details of contract services as submitted by CSPDCL (Rs. Cr.)
Sl. A&G R&M
Particulars
No. Exp. Exp.
1 Security services 2.01 -
2 Meter reading and other manpower service contracts 97.02 -
33/11 kV operations & Other manpower service
3 - 64.26
contracts
4 Grand Total 99.03 64.26

CSPDCL requested to consider the expenditure indicated in the above Table as


employee expenses rather than under controllable expenditure. CSPDCL submitted
that the methodology adopted by the Commission is causing double jeopardy to
CSPDCL as genuine expenses incurred towards distribution business are being
currently disallowed.
CSPDCL has calculated the normative A&G expenses and R&M expenses for FY
2021-22 by escalating the normative A&G expenses and R&M expenses of FY 2020-
21 with the increase in WPI of 13.00%.

168 CSERC Tariff Order FY 2022-23


For computation of sharing of gains/(losses), CSPDCL has not considered any gain
and loss on account of employee costs in line with the first amendment to the CSERC
MYT Regulations, 2015.
CSPDCL has submitted that it has computed sharing of (gain)/Loss after deducting
actual expenses incurred towards engagement of outsourced labour to perform
distribution business in lieu of amendments considered by the Commission in the
MYT Regulations, 2021.
CSPDCL has further submitted that as per the provisions of the MYT Regulations,
2021 the Commission has already made provisions to consider the expenses towards
outsourced manpower expenses under the head employee expenses. Further, Clause
83 of MYT Regulations, 2015 specifies as under:
“The Commission, for reasons to be recorded in writing, may relax any of the
provisions of these regulations on its own motion or on an application made
before it by an interested person.”
Thus, CSPDCL has submitted the sharing of efficiency gain against A&G expenses as
Rs. 52.88 Crore and efficiency loss against R&M expenses as Rs. 86.62 Crore for FY
2021-22, after excluding the A&G expenses and R&M expenses that have been
considered as employee expenses.

Commission’s View
The Commission had approved O&M expenses of Rs. 1,227.77 Crore in the Tariff
Order for FY 2021-22. As against this, CSPDCL has claimed actual O&M Expenses
of Rs. 1,396.30 Crore for FY 2021-22 based on audited accounts.

Actual O&M Expenses


CSPDCL has claimed actual employee expenses of Rs 848.85 Crore for FY 2021-22
based on the Audited Accounts. The Commission has verified the actual employee
expenses from the Audited Accounts of FY 2021-22, and allows the actual employee
expenses as claimed by CSPDCL.
CSPDCL has claimed A&G Expenses of Rs. 157.41 Crore in the final true-up for FY
2021-22. The Commission has verified these expenses from the Audited Accounts of
FY 2021-22, and allows the actual A&G expenses as claimed by CSPDCL.
CSPDCL has claimed actual R&M Expenses of Rs. 390.04 Crore for FY 2021-22.
The Commission has verified these expenses from the Audited Accounts of FY 2021-
22, and allows the actual R&M expenses as claimed by CSPDCL.
Accordingly, the actual O&M Expenses considered by the Commission for sharing of
gains and losses are given in the following Table:
Table 8-12: Actual O&M expenses as considered by the Commission (Rs. Crore)
Sl. Particulars Tariff Order Petition True-up
1 Employee Costs 947.51 848.85 848.85
2 A&G Expenses 145.26 157.41 157.41
3 R&M Expenses 135.00 390.04 390.04
4 Total O&M Expenses 1227.77 1396.30 1396.30

CSERC Tariff Order FY 2023-24 169


Normative O&M Expenses
Regulation 57.4 of the CSERC MYT Regulations, 2015 specifies as under:

(a) Operation and Maintenance (O&M) Expenses for the distribution licensee
shall include:
I. Employee Cost;
II. Administrative and general Expenses
III. Repairs and Maintenance Expenses
(b) The Commission shall stipulate a separate trajectory for each of the
components of O&M expenses viz. employee cost, R&M expense and A&G
expense for the control period.
(c) The employee cost, excluding pension fund contribution and impact of pay
revision arrears for the base year i.e. FY 2015-16 shall be derived on the
basis of the normalized average of the actual employee expenses,
excluding pension fund contribution and impact of pay revision arrears,
available in the accounts for the previous five years immediately preceding
the base year FY 2015-16, subject to prudence check by the Commission.
Any other expense of non-recurring nature shall also be excluded while
determining normalized average for the previous five years.
(d) The normalization shall be done by applying last five years average
increase in Consumer Price Index (CPI) on year to year basis. The
average of normalized net present value for FY 2010-11 to FY 2014-15,
shall then be used to project base year value for FY 2015-16. The base
year value so arrived, shall be escalated by the above inflation rate to
estimate the employee expenses (excluding impact of pension fund
contribution and pay revision, if any) for each year of the control period.
At the time of true-up the employee costs shall be considered after taking
into account the actual increase in CPI during the year instead of
projected inflation for that period.
Provided further that impact of pay revision (including arrears) and
pension fund contribution shall be allowed on actual during true-up as
per accounts, subject to prudence check and any other factor considered
appropriate by the Commission.”
Further, Regulation 57.4 (e) and (f) of CSERC MYT Regulations, 2015
regarding A&G Expenses and R&M Expenses specify as under:
“(e) The administrative and general expenses and repair and maintenance
expenses, for the base year i.e. FY 2015-16, shall be derived on the basis
of the normalized average of the actual administrative and general
expenses and repair and maintenance expenses, respectively available in
the accounts for the previous five (5) years immediately preceding the base
year FY 2015-16, subject to prudence check by the Commission. Any
expense of non-recurring nature shall be excluded while determining
normalized average for the previous five (5) years.

170 CSERC Tariff Order FY 2022-23


(f) The normalization shall be done by applying last five-year average
increase in Wholesale Price Index (WPI) on year to year basis. The
average of normalized net present value for FY 2010-11 to FY 2014-15,
shall then be used to project base year value for FY 2015-16. The base
year value so arrived, shall be escalated by the above inflation rate to
estimate the administrative and general expense and repair and
maintenance expenses for each year of the control period.
At the time of true up, the administrative and general expenses and
repair and maintenance expenses shall be considered after taking into
account the actual inflation instead of projected inflation for that
period.”
Based on the above Regulations, the Commission has considered the normative A&G
expenses and R&M expenses for FY 2021-22.
The Commission notes that CSPDCL has requested to treat expenses towards contract
services, viz., operations of 33/11 kV Substations, meter reading, bill distribution and
revenue collection, secretarial assistance in offices, housekeeping and security guards
under employee expenses and as uncontrollable. The MYT Regulations, 2015 do not
allow such treatment for A&G expenses and R&M expenses. In view of the above, the
Commission has not considered the prayer of the CSPDCL for consideration of
expenses for contract services as uncontrollable factor.
Further, CSPDCL‟s contention that the methodology adopted by the Commission is
causing double jeopardy to CSPDCL as genuine expenses incurred towards distribution
business are being disallowed, is incorrect, as expenses are not being disallowed. The
efficiency gains/losses are being shared between CSPDCL and the consumers in the
manner specified in the MYT Regulations, 2015.
The Commission has considered escalation factor of 13.00% for R&M expenses and
A&G Expenses for FY 2021-22 based on the applicable WPI.
The revised normative A&G expenses and R&M expenses approved for FY 2021-22
are shown in the Table below:
Table 8-13: Revised Normative R&M and A&G Expenses for FY 2021-22 (Rs. Crore)
Sl. Particulars Petition True-up
1 A&G Expenses 164.14 161.24
2 R&M Expenses 152.54 149.87
The Commission notified the CSERC MYT Regulations, 2016 (First amendment) on
June 16, 2017 and made it effective from April 1, 2017, whereby employee expenses
are excluded from accounting of sharing of gains/(losses). The relevant Regulation is
as under:
“In clause 13.1 of the principal regulations, the following proviso shall be
inserted, namely: -

Provided further that the employee cost shall not be factored in for
sharing of gains or losses on account of Operation and Maintenance
expenses”

CSERC Tariff Order FY 2023-24 171


In line with above amendment, the employee expenses are now considered as
uncontrollable expenses and therefore, the actual employee expenses approved in the
truing-up of FY 2021-22 after due prudence check, are considered without any
sharing of efficiency gains/losses. The Commission therefore, approves employee
cost of Rs. 848.85 Crore after Truing-up for FY 2021-22.
As per the provisions in the Regulations for sharing of gains/(losses) of O&M
expenses, the Commission has computed the efficiency gains/losses for FY 2021-22
on the basis of revised normative A&G expenses and R&M expenses, in accordance
with the CSERC MYT Regulations, 2015, as shown in the following Table:
Table 8-14: Sharing of (Gain)/Loss for FY 2021-22 (Rs. Cr.)
Entitlement of
Revised Actual Efficiency (Gain)/Loss
Particulars
Normative Expenses (Gain)/Loss
CSPDCL Consumers
A&G Expenses 161.24 157.41 (3.84) (1.92) (1.92)
R&M Expenses 149.87 390.04 240.18 120.09 120.09
Total 311.11 547.45 236.34 118.17 118.17

The Commission approves the sharing of efficiency loss of Rs. 118.17 Crore after
true-up for FY 2021-22.

8.7 Contribution to Pension and Gratuity


CSPDCL’s submission
CSPDCL claimed the contribution to Pension and Gratuity of Rs. 449.48 Crore for
FY 2021-22 as approved in the Tariff Order dated 2nd August 2021.

Commission’s View
The Commission has considered the contribution to Pension and Gratuity of Rs.
449.48 Crore for FY 2021-22 as approved in the Tariff Order dated 2nd Aug 2021.

8.8 Capital Structure


CSPDCL’s submission
CSPDCL has determined the capital structure for FY 2021-22 based on the following
principles:
(a) The actual loan addition for FY 2021-22 has been considered as Rs. 194.84
Crore based on the Audited Accounts;
(b) Addition in consumer contribution/grants has been considered as Rs. 679.46
Crore as per the Audited Accounts for FY 2021-22;
(c) Normative equity addition has been considered based on capital restructuring
methodology as approved by the Commission in the Tariff Order dated July
12, 2013;
(d) GFA addition has been considered as Rs. 1802.31 Crore as per the Audited
Accounts for FY 2021-22.

172 CSERC Tariff Order FY 2022-23


CSPDCL submitted the Capital Structure for FY 2021-22 as given in the Table below:
Table 8-15: Capital Structure for FY 2021-22 as submitted by CSPDCL (Rs. Crore)
Particulars Legend Petition
Gross Fixed Assets (GFA)
Opening GFA A 9,769.35
Opening CWIP B 3,284.50
Opening CAPEX C=A+B 13,053.85
Capitalization during the year D 1,802.31
Closing GFA E=D+A 11,571.66
Closing CWIP F 2,275.83
Closing CAPEX G=F+E 13,847.49
Grants and Consumer Contribution
Opening Grant and Contribution H 5,489.73
Consumer contribution/grants during the year I 679.46
Closing Consumer Contribution J=H+I 6,169.19
Consumer Contribution in Opening GFA K=H*A/C 4,108.45
Consumer Contribution in Closing GFA L=J*E/G 5,155.28
Loan Borrowed
Opening Borrowed Loan M 3,126.02
Loan Borrowed during the year N 194.84
Closing Borrowed Loan O=M+N 3320.86
Borrowed Loan in Opening GFA P=M*A/C 2,339.48
Borrowed Loan in Closing GFA Q=MAX (O*E/G, P) 2,775.08
Equity
Opening Gross Equity R=C-H-M 4,438.10
Equity Addition During the Year T=S-R (80.65)
Closing Gross Equity S=G-J-O 4,357.45
Gross Equity in Opening GFA U=A-K-P 3,321.42
Gross Equity in Closing GFA V=C-L-Q 3,641.30
Average Gross Equity During the year W=Avg. (U, V) 3,481.36
Funding of Capitalized Assets
Total Capitalization 1802.31
Contribution of Grant in Capitalized Assets 1046.83
Contribution of Equity in Capitalized Assets 226.64
Contribution of Loan in Capitalized Assets 528.84

Commission’s View
The approved closing balance after final True-up of FY 2020-21 has been considered
as the opening balance of FY 2021-22 for Gross Fixed Assets (GFA), Capital Work in

CSERC Tariff Order FY 2023-24 173


Progress (CWIP), Capital Expenditure, Grants/Consumer Contribution, Loan and
Equity.
The addition to GFA and Grant/Consumer Contribution has been considered for FY
2021-22 based on the Audited Accounts. The consumer contribution and grants have
been reduced from the GFA addition, before considering the normative debt:equity
ratio, in accordance with the MYT Regulations, 2015 and approach adopted in
previous Tariff Orders.
The GFA and its funding considered by the Commission for FY 2021-22 are shown in
the Table below:
Table 8-16: Approved GFA and Funding for FY 2021-22 (Rs. Crore)
Sl. Particulars Petition True-Up
Gross Fixed Assets (GFA)
1 Opening GFA 9,769.35 9,769.35
2 Capitalisation during the year 1,802.31 1,802.31
3 Closing GFA 11,571.66 11,571.66
Funding of Capitalisation
4 Grant 1,046.83 1,046.83
5 Equity 226.64 226.64
6 Debt 528.84 528.84
7 Total Capitalisation 1,802.31 1,802.31

The Commission approves the total capitalization of Rs. 1802.31 Crore and its
funding after true-up for FY 2021-22 as shown in the Table above.

8.9 Depreciation
CSPDCL’s Submission
CSPDCL submitted that depreciation has been calculated as per Regulation 24 of the
CSERC MYT Regulations, 2015. CSPDCL has claimed depreciation of Rs. 344.93
Crore for FY 2021-22.

Commission’s View
For the purpose of final true-up for FY 2021-22, the Commission has computed the
depreciation as per Regulation 24 of the CSERC MYT Regulations, 2015. The
Regulations provides for separate depreciation rates for each asset group.
Accordingly, the weighted average depreciation rates has been computed as 5.50% for
FY 2021-22.
The Commission has considered the depreciation on fully depreciated assets for FY
2021-22 as submitted by CSPDCL. The depreciation on fully depreciated assets has
been deducted in accordance with the approach adopted in the previous Tariff Orders.
Also, the depreciation on consumer contribution/Grants on live assets has been

174 CSERC Tariff Order FY 2022-23


deducted as per Regulation 24 of the MYT Regulations, 2015. Similarly, depreciation
on assets converted from loan to grant under UDAY has been deducted.
The depreciation approved after final True-up for FY 2021-22 is shown in the Table
below:
Table 8-17: Approved Depreciation for FY 2021-22 (Rs. Crore)
Tariff
Particulars Petition True-up
Order
Opening GFA 9,218.39 9,769.35 9,769.35
Additional Capitalisation during the Year 300.00 1,802.31 1,802.31
Closing GFA 9,518.39 11,571.66 11,571.66
Average GFA for the year 9,368.39 10,670.51 10,670.51
Depreciation Rates (%) 5.56% 5.50% 5.50%
Gross Depreciation 521.28 586.66 586.66
Less: Depreciation on consumer contribution on
226.50 176.62 176.62
live assets
Less: Depreciation on Fully Depreciated Assets 16.51 18.61 18.61
Less: Depreciation on assets converted from
46.20 46.20 46.20
loan to grant under UDAY
Net Depreciation 232.08 344.93 344.93

The Commission approves the total depreciation of Rs. 344.93 Crore after true-
up for FY 2021-22 as shown in the Table above.

8.10 Interest on Loan Capital


CSPDCL’s Submission
CSPDCL submitted that the Interest on loan capital has been computed in accordance
with Regulation 23 of the MYT Regulations, 2015. The allowable depreciation for the
year has been considered as the normative repayment for the year. The actual
weighted average interest rate of 8.87% has been considered for FY 2021-22 based on
the actual loan portfolio for the year. CSPDCL claimed the interest on loan capital as
Rs. 183.86 Crore for FY 2021-22.

Commission’s View
The closing Net normative loan approved in final True-up for FY 2020-21 has been
considered as opening net normative opening loan for FY 2021-22. Loan addition
during FY 2021-22 has been considered based on the approved capitalisation and
funding for FY 2021-22, as discussed in the Capital Structure earlier. The allowable
depreciation for the year has been considered as normative repayment for the year.
The Commission sought the documentary evidences for the opening loan balance and
applicable interest rate for each source of loan and the computation of weighted
average rate of interest for FY 2021-22. The actual weighted average interest rate has
been computed as 8.87% for FY 2021-22, based on the interest expenses paid against
the outstanding debt.
CSERC Tariff Order FY 2023-24 175
The interest expense approved for FY 2021-22 after final true-up is shown in the
Table below:
Table 8-18: Approved Interest Expenses for FY 2021-22 (Rs. Crore)
Tariff
Particulars Petition True-up
Order
Opening Net Normative Loan 1654.72 1928.10 1928.10
Repayment during the year 232.08 344.93 344.93
Normative loan addition during the year 178.64 528.84 528.84
Closing Net Normative Loan 1601.28 2112.00 2112.01
Average Normative loan during the year 1628.00 2020.05 2020.05
Weighted Average Rate of Interest 10.28% 8.87% 8.87%
Interest Expenses 167.36 179.12 179.18
Add: Other Finance Charges - 4.74 4.74
Total Interest on Loan 167.36 183.86 183.92

The Commission approves the Interest on Loan of Rs. 183.92 Crore after true-up
for FY 2021-22, as shown in the Table above.

8.11 Interest on Consumer Security Deposit


CSPDCL’s Submission
CSPDCL has considered the Interest on Consumer Security Deposit (CSD) paid to the
consumers in line with Regulation 6.13 of the Chhattisgarh Electricity Supply Code,
2011. Accordingly, the actual interest on CSD paid by CSPDCL is Rs. 97.12 Crore
for FY 2021-22 as per the Audited Accounts.

Commission’s View
The Commission has verified the actual interest paid on the CSD as per the Audited
Accounts for FY 2021-22. Accordingly, the Commission approves interest on CSD of
Rs. 97.12 Crore for FY 2021-22, as shown in the Table below:
Table 8-19: Approved Interest on CSD for FY 2021-22 (Rs. Crore)
Particulars Tariff Order Petition True-up
Interest on CSD 140.30 97.12 97.12

8.12 Interest on Working Capital


CSPDCL’s Submission
CSPDCL submitted that Interest on Working Capital (IoWC) has been computed as
per Regulation 25 of the MYT Regulations, 2015. For computation of working capital
requirement, CSPDCL has considered one month of the approved O&M expenses,
maintenance spares @ 40% of R&M expenses, and one month of receivables equal to
one month of expected revenue from sale of power. CSPDCL has considered the
interest rate of 10.90% for computing the IoWC for FY 2021-22.
CSPDCL submitted the normative IoWC as Rs. (120.41) Crore for FY 2021-22.

176 CSERC Tariff Order FY 2022-23


Commission’s View
The normative IoWC has been computed in accordance with the MYT Regulations,
2015. The Commission has considered the revised normative O&M expenses for
computing the working capital requirement. The receivables have been considered
equivalent to one month‟s actual revenue received. The average CSD has been
considered as Rs. 2,479.26 Crore for FY 2021-22, as per the Audited Accounts
submitted by CSPDCL. The interest rate for computing IoWC has been considered as
equal to the SBI Base Rate as on 1st April of 2021 (7.40%) plus 350 basis points, i.e.,
10.90% for FY 2021-22, in accordance with the MYT Regulations, 2015. The
normative IoWC for FY 2021-22 works out to be negative, as shown in the Table
below:
Table 8-20: Approved IoWC for FY 2021-22 (Rs. Crore)
Particulars Tariff Order Petition True-up
O&M Expenses for one month 102.31 97.13 96.66
Maintenance spares @ 40% of R&M
54.00 61.02 59.95
expenses
Receivables equal to 1 month of
1,346.86 1,216.43 1,216.43
revenue from sale of power
Total Working Capital 1,503.17 1,374.57 1373.04
Less: Security Deposit 2,750.84 2,479.26 2,479.26
Net Working Capital Requirement (1,247.67) (1,104.69) (1106.23)
Rate of Interest (%) 10.90% 10.90% 10.90%
Interest on Working Capital
(136.00) (120.41) (120.58)
requirement

The Commission approves the Interest on Working Capital of Rs. (120.58) Crore
after true-up for FY 2021-22, as shown in the Table above.

8.13 Return on Equity


CSPDCL’s Submission
CSPDCL has computed the Return on Equity (RoE) as per the capital structure
proposed by CSPDCL and as per Regulation 17.1 of the MYT Regulations, 2015.
CSPDCL has excluded consumer contribution, deposit work and grant from the asset
addition during the year for computation of normative debt:equity. CSPDCL has
considered rate of Return on Equity as 16% for FY 2021-22. CSPDCL has claimed
Return on Equity of Rs. 361.70 Crore for FY 2021-22.

Commission’s View
The RoE has been computed in accordance with Regulation 17 of the MYT
Regulations, 2015. The Commission has considered the closing permissible equity
approved for FY 2020-21, as the opening permissible equity for FY 2021-22. The
equity portion of the additional capitalisation for FY 2021-22 has been considered as
the equity addition for the year. The Commission has considered rate of return as 16%
on average equity for the year. The RoE approved after true-up for FY 2021-22 is
shown in the Table below:
CSERC Tariff Order FY 2023-24 177
Table 8-21: Approved RoE for FY 2021-22 (Rs. Crore)
Particulars Tariff Order Petition True-up
Permissible Equity in Opening GFA 2004.89 2,147.31 2,147.31
Permissible Equity in Closing GFA 2081.45 2,373.95 2,373.95
Average Equity during the year 2043.17 2,260.63 2,260.63
Rate of Return (%) 16.00% 16.00% 16.00%
Return on Equity 326.91 361.70 361.70

The Commission approves Return on Equity of Rs. 361.70 Crore after true-up for
FY 2021-22, as shown in the Table above.

8.14 Non-Tariff Income


CSPDCL’s Submission
CSPDCL submitted Non-Tariff Income (NTI) of Rs. 284.99 Crore for FY 2021-22
based on the Audited Accounts, comprising Rs. 69.74 Crore towards Non-Tariff
income and Rs. 215.25 Crore towards revenue from Wheeling Charges, Open Access
and Cross-Subsidy Charges. CSPDCL submitted that the amount of Rs. 249.98 Crore
considered under the head Other Income in the Audited Accounts of FY 2021-22
pertains to the amortization of Capital grants received and hence, is not of the nature
of income. This entry in the Audited Accounts is to meet the requirement of Ind-AS.

Commission’s View
The Commission notes that CSPDCL has claimed Non-Tariff Income of Rs. 284.99
Crore for FY 2021-22.
The Commission accepts CSPDCL‟s justification regarding non-consideration of the
amount of Rs. 249.98 Crore and has not considered this interest income under Non-
Tariff Income. The Commission has considered the actual Non-Tariff income for FY
2021-22 based on the audited accounts.
The Non-Tariff Income approved after true-up for FY 2021-22 is shown in the Table
below:
Table 8-22: Approved Non-Tariff Income for FY 2021-22 (Rs. Crore)
Particulars Tariff Order Petition True-up
Non-Tariff Income 241.16 69.74 69.74
Wheeling Charges, Open Access & CSS 76.87 73.35 73.35
POC 101.65 101.65
Meter rent 40.26 40.26
Total Non-Tariff Income 318.03 284.99 284.99

The Commission approves Non-Tariff Income of Rs. 284.99 Crore after true-up
for FY 2021-22.

8.15 Aggregate Revenue Requirement


The summary of ARR approved in the True-up for FY 2021-22, based on the
approved values of different components of the ARR, is shown in the Table below:

178 CSERC Tariff Order FY 2022-23


Table 8-23: Approved ARR for FY 2021-22 (Rs. Crore)
Tariff
Sl. Particulars Petition True-up
Order
A Gross Power Purchase Expenses 14,446.33 16112.50 15792.38
1 Power Purchase Cost 12801.73 14180.60 13852.30
2 Inter-State Transmission Charges 603.93 957.53 957.53
3 Intra-State Transmission Charges 1025.74 962.50 967.64
4 CSLDC Charges 14.93 11.87 14.90
B Operation & Maintenance Expenses 1,677.26 1,845.79 1845.78
1 Net Employee Expenses 947.51 848.85 848.85
2 Net A&G Expenses 145.26 157.41 157.41
3 Net R&M charges 135.00 390.04 390.04
4 Pension & Gratuity 449.48 449.48 449.48
C Interest & Finance Expenses 171.66 160.57 160.46
1 Interest on Loan 167.36 183.86 183.92
2 Interest on Security Deposit 140.30 97.12 97.12
3 Interest on Working Capital Requirement (136.00) (120.41) (120.58)
D Other Expenses 558.99 706.63 706.63
1 Depreciation 232.08 344.93 344.93
2 Return on Equity 326.91 361.70 361.70
E Gain/(Loss) on Efficiency (33.74) (255.36)
1 Gain/(Loss) on Sharing O&M Efficiency (33.74) (118.17)
Gain/(Loss) on account of Distribution
2 (137.19)
Losses
F Less: Non-Tariff Income 318.03 284.99 284.99
1 Non-Tariff Income 241.16 69.74 69.74
Wheeling Charges, Open Access & Cross
2 76.87 215.25 215.25
Subsidy Charges, POC, Meter rent
G Aggregate Revenue Requirement 16536.21 18506.76 17964.91
Note: The revenue from sale of power to Telangana, surplus power, and UI sale have been
considered under Revenue, in the true-up for FY 2021-22

8.16 Revenue from Sale of Power


CSPDCL’s Submission
CSPDCL submitted the total revenue from sale of power as Rs. 16,451.29 Crore for
FY 2021-22 as per Audited Accounts, as against revenue of Rs. 15,220.40 approved
by the Commission in the Tariff Order, including the revenue of Rs. 1854.14 Crore
from sale of surplus power and sale of power to Telangana.

Commission’s View
The Commission notes that CSPDCL has submitted the revenue from sale of power as
Rs. 16,451.29 Crore for FY 2021-22 based on the audited accounts of FY 2021-22.
As per the methodology adopted in previous Tariff Orders, the Commission has
treated revenue on account of sale of surplus power as revenue in the true-up for FY
2021-22. These amounts have been discussed in earlier Section of this Order.

CSERC Tariff Order FY 2023-24 179


Further, the Commission observes that the actual Average Billing Rate (ABR)
realised for Agriculture category continues to be lower than the approved ABR.
CSPDCL has submitted in the past that the variation in the actual ABR and approved
ABR is because of implementation of Government of Chhattisgarh notification on flat
rate tariff. Government of Chhattisgarh (GoCG) is providing subsidy to Agriculture
consumer up to 5 HP since November 2, 2009. After this, directive was issued vide
Notification dated September 19, 2013 permitting the farmers to option of billing on
flat rate basis for agriculture pumpsets.
From the subsidy notification, it is observed that if the consumer opts for subsidy
against flat rate tariff, then there is no consumption limit for the consumer, however,
the subsidy to CSPDCL has been capped at the level equivalent to 6000 units per year
and 7500 units per year for 3 HP and 5 HP pumpsets, respectively. This anomaly in
capping of consumption is leading to the under-recovery of revenue against this
category.
The Commission, in the previous Tariff Orders, has adopted the approach of
consideration of additional revenue for Agriculture Category, as CSPDCL is bound to
levy the tariff approved by the Commission in its respective Tariff Order for all
categories including Agriculture consumers. Any form of subsidy given by the State
Government is a relief to that category of consumers and therefore, part of the
approved tariff is to be recovered in the form of subsidy from the Government and the
balance part is to be levied to consumers of that category. Overall, CSPDCL is liable
to recover the tariff approved by the Commission.
Accordingly, the additional revenue to be considered against the Agriculture category
is shown in the Table below:
Table 8-24: Additional Revenue from Agriculture Category for FY 2021-22
Difference
Average
Energy Approved between Additional
No. of Actual
Consumer Unit Sold Charge Energy Approved & Revenue to be
MONTH Consu- Energy
Category (MU) Billed (Rs. Charge Actual Energy considered
mers Charge
Crore) (Rs./kWh) Charge (Rs. Crore)
(Rs./kWh)
(Rs./kWh)
1 2 3 4 5 6 7 8 9
4 MONTH 143356 274.01 119.71 4.37 4.4 -0.03 0.85
A - METERED
8 MONTH 148613 635.83 297.5 4.68 4.9 -0.22 14.06
KJJY
YEAR 148613 909.84 417.21 4.59
4 MONTH 177873 605.79 194.36 3.21 4.4 -1.19 72.19
B - FLAT RATE
8 MONTH 186225 1226.1 446.52 3.64 4.9 -1.26 154.27
KJJY
YEAR 186225 1831.89 640.88 3.50
GENERAL / 4 MONTH 147340 648.96 285.26 4.40 4.4 0.00 0.28
OTHER PUMP 8 MONTH154826 1429.61 697.84 4.88 4.9 -0.02 2.67
CONSUMERS YEAR
154826 2078.57 983.11 4.73
4 MONTH 114115 332.49 121.51 3.65 4.4 -0.75 24.79
TEMPORARY
8 MONTH 124467 681.81 273.93 4.02 4.9 -0.88 60.16
CATEGORY
YEAR 124467 1014.3 395.44 3.90
4 MONTH 582684 1861.24 720.85 3.87 4.4 -0.53 98.11
TOTAL 8 MONTH 614131 3973.35 1715.78 4.32 4.9 -0.58 231.15
YEAR 614131 5834.59 2436.64 4.18 329.26

180 CSERC Tariff Order FY 2022-23


Thus, there is under-recovery of energy charge, i.e., of Rs. 0.53/kWh for four months
and 0.58/kwh for eight months for FY 2021-22, which translates to under-recovery of
Rs. 329.26 Crore for FY 2021-22.
In view of the above, the Commission has considered the amount of Rs. 329.26
Crore as an additional revenue while approving the final true-up for FY 2021-22.
The Commission has accordingly considered total Revenue for FY 2021-22 as shown
in the Table below:
Table 8-25: Approved Revenue for FY 2021-22 (Rs. Crore)
Tariff
Particulars Petition True-up
Order
Revenue from Retail Sale of Electricity 15,220.40 14,597.15 14597.15
Add: Subsidy from State Government -
Add: Additional revenue for Agriculture
329.26
Metered category
Add: Revenue from sale of Power to
1854.14 1947.42
Telangana and Surplus Power
Total Revenue from Sale 15,220.40 16,451.29 16873.82

The Commission approves total revenue of Rs. 16,873.82 Crore after true-up for
FY 2021-22, after including revenue from sale of surplus power.

8.17 Revenue Gap/(Surplus)


CSPDCL’s Submission
CSPDCL has submitted a standalone Revenue Gap of Rs. 2055.47 Crore for FY
2021-22. Further, after considering the adjustment of past Revenue Gaps/(Surplus),
impact of Review Petition filed by CSPDCL, and the associated carrying cost,
CSPDCL has submitted the cumulative Revenue Gap at the end of FY 2021-22 as Rs.
5,758.68 Crore.

Commission’s View
The Commission has considered the ARR approved for CSPDCL after true-up for FY
2021-22 and the Revenue approved in the earlier Sections of this Chapter, to compute
the Revenue Gap/(Surplus) for FY 2021-22. Further, the Commission has considered
the Past Gap/(Surplus) considered by the Commission for CSPDCL, CSPGCL,
CSPTCL and CSLDC, while approving the ARR and Tariff of CSPDCL for FY 2021-
22, for correct computation of the Revenue Gap/(Surplus) after true-up. The impact of
Review Petition has been considered as Nil, based on the reasoning elaborated in the
previous Chapter of this Order.
The summary of Revenue Gap/(Surplus) approved after true-up of FY 2021-22 for
CSPDCL is shown in the Table below:

CSERC Tariff Order FY 2023-24 181


Table 8-26: Approved Revenue Gap/(Surplus) for FY 2021-22 (Rs. Crore)

Sl. Tariff
Particulars Petition True-up
No. Order
1 Net ARR 13,416.12 18,506.76 17964.91
2 Revenue from Sale of Power 15220.40 16,451.29 16873.82
3 Standalone Revenue Gap/(Surplus) (1,804.28) 2055.47 1091.08
4 Add: Revenue Gap/(Surplus) carried forward
from final true-up of FY 2019-20 for 329.75 329.75 329.75
CSPGCL
Gap/ (Surplus) after true-up of CSPGCL RE
(5.72) (5.72) (5.72)
Station (Order in Petition No. 16/2021)
Additional NTI to CSPGCL from sale of
(10.00) (10.00) (10.00)
scrap of KTPS
5 Add: Revenue Gap/(Surplus) carried forward
from final true-up of FY 2019-20 for (46.06) (46.06) (46.06)
CSPTCL
6 Add: Revenue Gap/(Surplus) carried forward
(3.63) (3.63) (3.63)
from final true-up of FY 2019-20 for CSLDC
7 Add: Revenue Gap/(Surplus) carried forward
from final true-up of FY 2019-20 for 2235.39 2235.39 2235.39
CSPDCL
Regulatory Asset for CSPDCL 246.44 246.44 246.44
8 Add: Revenue Gap for Review Petition after
518.03 -
Final True Up for FY 2020-21
9 Closing Revenue Gap/(Surplus) 941.89 5,319.67 3837.25
10 Rate of Interest (%) 10.90% 10.90%
11 (Carrying)/Holding cost 0.00 439.01 59.46
12 Total Closing Revenue Gap/(Surplus) at end
941.89 5,758.68 3896.72
of the year

The Commission approves cumulative Revenue Gap of Rs. 3,896.72 Crore at the
end of FY 2021-22 for CSPDCL. This Revenue Gap has been adjusted against
the ARR of CSPDCL for FY 2023-24, along with the due Carrying Cost, as
discussed in subsequent Chapter.

182 CSERC Tariff Order FY 2022-23


9 ARR OF CSPDCL FOR FY 2023-24
9.1 Background
CSPDCL submitted the projected ARR for FY 2023-24 under various heads, viz.,
Sales, Power Purchase expenses, O&M expenses, depreciation, interest on loans,
interest on working capital, etc., in accordance with the CSERC MYT Regulations,
2021. The Commission has approved the revised ARR for FY 2023-24 in accordance
with the provisions of the MYT Regulations, 2021, in the following sections.

9.2 Sales Projections


CSPDCL’s Submission
CSPDCL submitted that there are various factors, which can have an impact on the
actual consumption of electricity and are often beyond the control of the Licensee,
such as Government Policy, economic climate, weather conditions, force-majeure
events like natural disasters, change in consumption mix, etc. Hence, various factors
affecting electricity consumption were considered and interrelationships have been
estimated among them to arrive at the forecast of energy sales within a range for the
purpose of estimating future costs/revenues. CSPDCL submitted that in the MYT
Regulations, 2021, sales mix and quantum of sales are considered as uncontrollable.
CSPDCL submitted that for projecting the category-wise energy sales for FY 2023-
24, it has considered the past growth trends for each consumer category as per the
categorisation approved in the latest Tariff Order.
CSDPCL submitted that Compounded Annual Growth Rates (CAGR) of sales have
been computed from the past sales for each category, corresponding to different
lengths of time in the past three years, i.e., FY 2019-20, FY 2020-21, and FY 2021-22
for LV category and FY 2018-19, FY 2019-20, FY 2020-21, and FY 2021-22 for HV
category. CSPDCL submitted that the consideration of separate duration of years
period for LV and HV category is to avoid the effect of COVID-19 period in future
projections, as industrial consumption has been affected adversely during COVID-19
period.
Subject to the specific characteristics of each consumer category, three-year CAGR
has been chosen as the basis of sales projection for that category. For example, if an
abnormal growth rate (high or low), relative to the current trend, is observed at the
beginning of the three-year period considered, then a shorter period is considered for
the trend analysis and projections. In cases where the past data shows a declining
trend, nil growth has been considered. Similarly, an inconsistent trend has been
substituted with assumptions of growth.
Further, for projection of number of consumers, sales and connected load of sub-
categories/slabs of any consumer category, CSPDCL has used the ratio of provisional
sales in the sub-category to total sales of the category observed in FY 2021-22.
Further, the actual sales, connected load and number of consumers has been shown as
per old categories/ sub-categories as approved in the MYT Order dated 13th April,
2022.
CSPDCL has projected the category-wise sales for FY 2023-24, as shown in the Table
below:

CSERC Tariff Order FY 2023-24 183


Table 9-1: Category-Wise Sales Projected by CSPDCL for FY 2023-24
Sl.
Category Description Category CAGR (%) FY 2023-24
No.
A LV
1 Domestic Including BPL
LV 1 7.78% 7,230.30
Consumers
2 Non-Domestic Normal LV 2.1 0.00% 266.20
3 Non-Domestic Demand
LV 2.2 10.00% 897.22
Based
4 Agriculture LV 3 6.61% 5,478.22
5 Agriculture Allied Activities LV 4 16.58% 42.17
6 Industry LV 5 9.92% 805.56
7 Public Utilities LV 6 10.00% 563.93
8 IT & Textile Industries LV 7 10.00% 1.45
9 Temporary LV 8 10.00% 1,366.11
B HV
1 Railway Traction HV 1 6.69% 1,319.89
2 Mines HV 2 4.18% 741.34
3 Other Industrial & General
HV 3 1.95% 1,953.12
Purpose Non-Industrial
4 Steel Industries HV 4 7.50% 7,733.01
6 Irrigation & Agriculture
HV 5 18.76% 269.79
Allied Activities, PWW
7 Residential HV 6 1.23% 182.30
8 Start Up Power HV 7 10.00% 22.55
9 Industries related to
manufacturing of equipment HV 8 10.00% 3.53
for RE power generation
10 IT & Textile Industries HV 9 10.00% 8.76
11 Temporary HV 10
C Total (A+B) 28,885.46

Commission’s View
The Commission has obtained the actual sales in the 8-month period from April to
November 2022, and estimated the category-wise sales for FY 2022-23. The
Commission has considered the estimated sales for FY 2022-23 as the base year sales,
for the purpose of projection of revised sales for FY 2023-24.
The Commission has computed the 5-year/4-year/3-year/2-year CAGR and Year-on-
Year (YoY) growth in sales for each LT and HT category based on the actual
category-wise sales up to FY 2021-22. The most appropriate growth rate has been
considered for projecting the category-wise sales for the Control Period, over the sales
estimated for FY 2022-23, as discussed above. For instance, for categories where a

184 CSERC Tariff Order FY 2022-23


clear and consistent trend in sales is seen, the 5-year CAGR reflecting the longer-term
trend has been considered for projecting the sales for FY 2023-24. In cases where
there is no clear trend visible, the shorter-term trend has been considered for making
the estimates.
For projection of sales for sub-categories/consumption slabs of any consumer
category, the ratio of sales in the sub-category/consumption slab to total sales of the
category estimated for FY 2022-23 has been applied to the sales projected for the
category for FY 2023-24.
The category-wise connected load/Contract Demand and number of consumers have
also been projected on similar basis.
The sales projected by CSPDCL and the sales approved by the Commission for each
consumer category is shown in the Table below:
Table 9-2: Approved Category-Wise Sales for FY 2023-24 (MU)
CSPDCL
Sl. Approved
Category Description Petition
No.
FY 2023-24 FY 2023-24
A LV 16,651.16 16,826.48
1 Domestic Including BPL Consumers 7,230.30 7,276.32
2 Non-Domestic Normal 266.20 343.02
3 Non-Domestic Demand Based 897.22 943.91
4 Agriculture 5,478.22 5,618.43
5 Agriculture Allied Activities 42.17 39.15
6 Industry 805.56 719.31
7 Public Utilities 563.93 610.15
8 IT & Textile Industries 1.45 1.36
9 Temporary 1,366.11 1,274.83
B HV 12,234.30 13,808.22
1 Railway Traction 1,319.89 1,305.90
2 Mines 741.34 725.26
Other Industrial & General Purpose Non-
3 1,953.12 2,327.73
Industrial
4 Steel Industries 7,733.01 9,000.02
6 Irrigation & Agriculture Allied Activities, PWW 269.79 249.56
7 Residential 182.30 180.73
8 Start Up Power 22.55 11.64
Industries related to manufacturing of equipment
9 3.53 4.80
for RE power generation
10 IT & Textile Industries 8.76 2.58
11 Temporary
C Total (A+B) 28,885.46 30,634.70

9.3 Inter-State Transmission Losses


CSPDCL’s Submission
CSPDCL has considered actual weighted average all-India transmission loss of last 12
months, as the same practice is adopted by all State Commissions and is more
practical as it captures varying loss. CSPDCL requested the Commission to consider
the inter-State transmission losses as 3.42%.

CSERC Tariff Order FY 2023-24 185


Commission’s View
The inter-State transmission losses have been considered as 3.42%, as proposed by
CSPDCL, for the purpose of computing the energy available to CSPDCL from its
inter-State generation sources.

9.4 Intra-State Transmission Losses


CSPDCL’s Submission
CSPDCL has considered the intra-State Transmission Loss as 3.00% for FY 2023-24
based on the Transmission Loss approved by the Commission in its latest tariff order
(Order dated 13.04.2022).

Commission’s View
The intra-State transmission losses have been considered as 3.00% for FY 2023-24, as
approved in the MYT Order dated 13.04.2022, for the purpose of computing the
energy requirement for CSPDCL.

9.5 Distribution Losses


CSPDCL’s Submission
CSPDCL submitted that Regulation 98 of the CSERC MYT Regulations, 2021
specifies as under:
“98 ENERGY LOSSES FOR DISTRIBUTION SYSTEM
98.1. The energy loss for 33 KV and below voltage level, shall be computed as
per relevant provision(s) of the State Grid Code 2011 as amended from time to
time. The difference between the energy injected at 33 KV voltage level and the
sum of energy sold to all its consumers (retail and open access), at voltage level
33 KV and below shall be the energy loss for the 33KV and below system. The
same shall be considered for the gain/ loss at the time of true up.
98.2. Energy sold shall be the sum of metered sales and assessed unmetered
sales, if any, based on prudence check by the Commission.
98.3. Energy Loss trajectory f'or distribution licensee shall be as specified by the
Commission in the tariff order.”
CSPDCL submitted that the Regulations provide that the Distribution Losses shall be
specified by the Commission in the Tariff Order. The Ministry of Power vide its Office
Memorandum No. 20/9/2019-IPDS provided the details of “Revamped Distribution
Sector Scheme” with the objective of reduction of AT&C loss at pan-India level to 12-
15% by FY 2024-25. The terms and conditions of the aforesaid scheme require
approval of the State Government, which is pending so far. CSPDCL has considered
the latest approved target of 15.33% for FY 2023-24 as the same has been stipulated by
the Commission vide its MYT Order dated 13.04.2022. CSPDCL added that the
aforesaid distribution loss trajectory projections would change in case the Revamped
Distribution Sector Scheme (RDSS) is implemented in the State.

186 CSERC Tariff Order FY 2022-23


Commission’s View
The Commission had approved the Distribution Loss level of 15.33% for FY 2023-24,
as approved in the MYT Order dated 13.04.2022.
Table 9-3: Approved Distribution Losses for FY 2023-24 (%)

CSPDCL
Sl. No. Particulars Approved
Petition

A Distribution Losses 15.33% 15.33%

The Commission may further revise the Distribution Loss levels for the Control Period
depending on the capital investments being made under RDSS.

9.6 Energy Balance


CSPDCL’s Submission
CSPDCL has submitted the Energy Balance for FY 2023-24 based on the projected
sales, and trajectory proposed for Distribution Losses, inter-State Transmission
Losses, and intra-State Transmission Losses, as shown in the Table below:
Table 9-4: Energy Balance Projected by CSPDCL for FY 2023-24 (MU)
CSPDCL
Sl. Particulars Legend
Petition
1 LV Sales A 16,651.16
2 HV Sales B 7,926.57
3 Total Below EHV Level C=A+B 24,577.73
4 Energy Loss below 33 kV (in %) D 15.33%
5 Energy Loss below 33 kV (in MU) E 3,767.77
Gross Energy requirement at 33 kV
6 F=C+E 28,345.49
Level
Less: Direct Input to distribution at
7 G 351.77
33 kV Level
Net Energy Input required at
8 Distribution Periphery at 33 kV H=F-G 27,993.72
Level
9 Sales to EHV consumers I 4,307.73
Net energy requirement at
10 J=H+I 32,301.45
Distribution periphery
Distribution loss including EHV
11 K 11.54%
Sales

Commission’s View
The Commission has approved the Energy Balance for FY 2023-24 based on the
approved sales, and approved trajectory for Distribution Losses, inter-State
Transmission Losses, and intra-State Transmission Losses, as shown in the Table
below:

CSERC Tariff Order FY 2023-24 187


Table 9-5: Approved Energy Balance for FY 2023-24
CSPDCL
Particulars Legend Approved
Petition
LV Sales A 16,651.16 16,826.48
HV Sales B 7,926.57 8,613.35
Total Below EHV Level C=A+B 24,577.73 25,439.83
Energy Loss below 33 kV (in %) D 15.33% 15.33%
Gross Energy requirement at 33 kV Level E=C/(1-D) 28,345.49 30,045.86
Energy Loss below 33 kV (in MU) F=E-C 3,767.77 4,606.03
Less: Direct Input to distribution at 33 kV Level G 351.77 351.77
Net Energy Input required at Distribution
27,993.72 29,694.09
Periphery at 33 kV Level H=E-G
EHV Sales I 4,307.73 5,194.87
Net energy requirement at Distribution
32,301.45 34,888.96
periphery J=H+I
Distribution loss including EHV Sales (in %) K 11.54% 13.07%
Intra-State Transmission loss (in %) L 3.00%
Intra-State Transmission loss (in MU) M 1,079.04
Net energy requirement at Transmission
35,968.00
periphery N=J+M
Inter-State Transmission loss (in MU) O 518.53
Net Power Purchase requirement P=N+O 36,486.53

9.7 Power Purchase Quantum and Cost


CSPDCL’s Submission
CSPDCL submitted that it had broadly categorised the sources of energy into
Allocation (firm and non-firm) from Central Generating Stations (CGS), State Owned
Generation, i.e., Generation from CSPGCL, Solar Power Plants, Independent Power
Producers (IPPs), and Short-Term/Bilateral purchases, etc. CSPDCL added that the
plants, which are scheduled to commence generation during FY 2023-24 are
Renewable Energy (RE) plants only and it has considered the availability from such
new plants.
CSPDCL has projected the purchase of power from various sources as detailed below.

i. Existing Central Generating Stations


CSPDCL submitted that it has firm allocation of power from Central Generating
Stations (CGS) like Korba Super Thermal Power Station (STPS), Vindhyachal
Thermal Power Station, Sipat Super Thermal Power Station, Kahalgaon Super
Thermal Power Station, Mauda Super Thermal Power Station, Solapur Super Thermal
Power Station, Tarapur Atomic Power Stations and Lara Super Thermal Power
Station (STPS) Unit I, etc. to meet its energy requirement.

188 CSERC Tariff Order FY 2022-23


The power purchase cost mainly comprises fixed charges and energy charges for two-
part tariff stations, i.e., NTPC, NPCL, and others. As CERC has issued the Tariff
Order for Annual Fixed Charges (AFC) of CGS for the Control Period (FY 2019-20
to FY 2023-24), CSPDCL has considered the fixed charges for the generating stations
whose Tariff Orders are issued by CERC and for other generating stations as allowed
by the Commission in MYT Order dated 13.04.2022 for FY 2022-23 and FY 2023-24
for projecting power purchase expenses for FY 2023-24. The existing rates of energy
charges of FY 2021-22 are considered. CSPDCL while estimating the costs, has
considered only the fixed and energy charge and has estimated that any cost over and
above would be passed through on actual basis.
CSPDCL has estimated the gross energy availability from the existing stations based
on the allocated capacity and the actual average Plant Load Factor (PLF) for the past
five years sourced from CEA and same has been considered for FY 2023-24.

ii. State Generating Stations


CSPDCL submitted that it mainly relies on the power from State Generating Stations,
i.e., CSPGCL stations. Currently, it has allocation of 2985 MW from CSPGCL.
Availability of State Generating Stations other than Marwah has been considered on
actual basis, with availability from Marwah being considered at 70% PLF based on
conservative approach after commissioning of Captive Coal mine.
For estimating the cost of power purchase from CSPGCL, CSPDCL has considered
the fixed charges as approved by the Commission in the Tariff Order dated 13th April
2022. CSPDCL while projecting energy charges for FY 2023-24 has considered
actual energy charges approved by the Commission vide Order dated 13.04.2022 for
FY 2023-24 after reducing 10% of the Variable cost adjustment (VCA) estimated on
the basis of actual variable cost adjustment made during FY 2021-22. For FY 2023-
24, it has considered no escalation for projection of energy charges and has estimated
that any cost over and above would be passed though on actual basis.
CSPDCL has not considered any sale of the power of Marwa to Telangana at State
periphery for FY 2023-24 as no power is supplied to Telangana State unless the State
pays the long-pending dues to CSPDCL.

iii. Power Purchase from RE Sources


CSPDCL submitted that the Commission in its CSERC (Renewable Purchase
Obligation and REC Framework Implementation) Regulations, 2021 notified on 29th
October 2021 has specified the RPO trajectory till FY 2023-24. Accordingly,
CSPDCL has considered the RPO obligation for FY 2023-24.
Table 9-6: RPO Target for FY 2023-24 (%)
Sl.
Particulars FY 2023-24
No.
1 Solar 12.50%
2 Non-Solar (HPO) 0.66%
3 Non-Solar (Others) 10.50%

CSERC Tariff Order FY 2023-24 189


CSPDCL has also considered purchase from new RE plants. CSPDCL has envisaged
that additional RE capacity of 2373 MW would be commissioned in the Control
Period from FY 2022-23 to FY 2023-24. The details of RE capacity addition with
expected commissioning date is given in the Table below:
Table 9-7: RE Capacity Addition envisaged for FY 2023-24
Sl. Capacity Expected
Source
No. (MW) Commissioning Date
1 SECI (Wind) 300 22-04-2022
2 SECI(Hybrid) 400 01-11-2021
3 SECI (Solar+BESS) 100 01-04-2023
4 NHPC (Solar) 400 01-04-2022
5 SECI (Hybrid) 400 01-01-2023
6 SECI (Blended wind) 170 01-06-2021
7 MBPCL 113 01-10-2023
8 SECI (Solar +Manufacturing) 300 01-10-2023
9 NTPC Solar 190 01-04-2022
10 Total 2373

CSPDCL submitted that after availability of cheaper non-solar RE sources due to


expected commissioning of dedicated wind as well as blended wind source during the
Control Period, CSPDCL has not considered availability from biomass generating
stations for estimation of power purchase expenses. This estimation is in line with the
Commission‟s views in the Tariff Order dated 13th April 2022 on management of
surplus power sale and economic despatch principles. CSPDCL requested the
Commission to consider biomass stations under the purview of Merit Order Despatch
in the best interest of power purchase cost as these stations contain two-part Tariff and
are not intermittent in nature like Wind Generating Stations. CSPDCL stated that
there would be a fixed cost liability arising out of non-scheduling of electricity and
CSPDCL may be allowed to claim actual expenditure towards payment of its fixed
cost towards biomass generators at the time of True up for the respective year.

iv. Concessional Power Purchase


The quantum and rate of concessional power purchase have been considered as
projected by CSPDCL @ Rs. 1.86/kWh, however, it is clarified that for the generators
whose tariff has already been determined for any financial year, energy charges for
FY 2023-24 shall be billed at the latest tariff determined by the Commission.

v. Transmission – Inter, Intra & CSLDC Charges


CSPDCL has to pay transmission charges to PGCIL for use of transmission facilities
enabling power drawal from the Western and Eastern Region. CSPDCL has
considered the PGCIL charges at same levels as approved by the Commission in the
Tariff Order dated 13th April 2022 for FY 2023-24.

190 CSERC Tariff Order FY 2022-23


The Intra-State Transmission Charges and CSLDC charges have also been considered
at the same level as approved by the Commission in the Tariff Order dated 13th April
2022 for FY 2023-24.

vi. Interstate sale


CSPDCL has submitted that the sale of electricity other than to retail consumers is not
within the regulatory purview of the Commission. As electricity cannot be stored, the
surplus energy has to be sold as and when available at the market realised rates. The
availability of surplus energy is dependent on the consumption of the consumers and
not on the Licensee. The sale of surplus energy is always ensured to be sold with the
objective of maximising the revenue from such sale and to pass on the accrued benefit
to the retail consumers.

Commission’s View
CSPDCL's submissions and assumptions have been analysed in detail and additional
information was asked on the same. The power purchase expenses have been
estimated based on the power purchase requirement as approved above. CSPDCL's
projections of quantum of power available from different sources and the rate of
purchase from different sources have been accepted, with the following
modifications:
a) The quantum and rate of power purchase from CGS have been considered as
projected by CSPDCL, except for purchase from a few stations;
b) No escalation has been considered on the rate of power purchase from any
source, as the variation in rates will be adjusted through the FCA and VCA
mechanism;
c) The quantum and rate of power purchase from CSPGCL Stations have been
considered as considered by CSPDCL in its calculations;
d) Purchase from Traders/Power Exchanges and other short-term sources have
been considered as Nil for FY 2023-24 in view of the overall surplus power
availability.
e) The quantum and rate of concessional power purchase have been considered as
projected by CSPDCL;
f) The Commission has considered the fixed cost of biomass power sources based
on actuals of FY 2022-23; however, no quantum of purchase has been
considered from biomass sources based on merit order despatch principles, as
the variable cost of these sources is on the higher side;
g) The Commission has considered the quantum and cost of purchase from existing
and new RE sources as projected by CSPDCL for FY 2023-24;
h) In case of shortfall in meeting the RPO targets on account of delay in the
commissioning of new RE plants or lesser generation from the existing RE
plants, CSPDCL should ensure that the RPO targets are met through purchase
from other RE sources or RECs, etc.;
i) The inter-State transmission charges payable to PGCIL have been considered as
same as approved in the Tariff Order dated 13th April 2022.
j) The Intra-State Transmission Charges also have been considered as same as
approved in the Tariff Order dated 13th April 2022;

CSERC Tariff Order FY 2023-24 191


k) The CSLDC charges have been considered as same as approved in the Tariff
Order dated 13th April 2022;
l) The statutory and other charges such as water charges, SLDC charges, start-up
power charges, etc., incurred by CSPGCL have also been included in the power
purchase expenses based on the actuals of FY 2021-22, as these are reimbursed
to CSPGCL at actuals, in order to reflect the power purchase expenses more
realistically;
m) The revenue from sale of surplus energy has been considered separately at the
latest rates, and has not been shown as a reduction of power purchase costs.
The approved quantum and cost of power purchase from different sources of power
for FY 2023-24 are given in the Table below:
Table 9-8: Approved Power Purchase Quantum and Cost for FY 2023-24
CSPDCL Petition Approved
Per unit Per unit
Sl. Particulars Amount Amount
Quantum Rate Quantum Rate
(in Rs. (in Rs.
(in MU) (Rs/ (in MU) (Rs/
Crore) Crore)
kWh) kWh)
A Purchase from Central Generating Stations
1 NTPC 13866.74 4578.64 3.30 13205.52 5071.70 3.84
2 NTPC - SAIL 279.94 133.49 4.77 279.94 133.49 4.77
3 NPC Limited 277.93 94.34 3.39 277.93 94.46 3.39
4 Others 648.28 408.28 6.30 105.25 19.22 1.83
5 NTP New 543.04 389.06 7.16
Sub Total A 15072.89 5214.74 3.46 14411.66 5707.93 3.96
B Purchase from Thermal and Hydel State Generating Stations
5 CSPGCL – Thermal 18023.59 6076.01 3.37 18023.59 6370.29 3.53
CSPDCL -
6 674.25 71.30 1.06 674.25 71.62 1.06
Renewables
Sub Total B 18697.84 6147.31 3.29 18,697.84 6441.91 3.45
C Purchase from Traders, IPPs, and others sources
7 Short-term Purchase - - - - - -
8 Concessional Power 2395.56 444.52 1.86 2395.56 444.52 1.86
Sub Total C 2395.56 444.52 1.86 2395.56 444.52 1.86
D Purchase from Renewable Sources
9 Biomass 0.00 0.00 0.00 - 115.50 -
10 Solar 1994.01 754.86 3.79 960.33 240.08 2.50
11 Hydel/Other RE 464.72 158.64 3.41 464.72 158.47 3.41
12 Other/New RE 2236.91 559.23 2.50 3270.59 817.65 2.50
Sub Total D 4695.64 1472.73 3.14 4695.64 1331.70 2.84
Gross power
E 40861.93 13279.30 3.25 40200.70 13926.06 3.46
purchase Cost
F Transmission & Other Charges
Inter-State
13 - 724.69 - - 724.69 -
Transmission Charges
Intra-State
14 - 1155.61 - - 1155.61 -
Transmission Charges
15 CSLDC Charges - 19.55 - - 19.55 -
Sub Total F - 1899.85 - - 1899.85 -

192 CSERC Tariff Order FY 2022-23


CSPDCL Petition Approved
Per unit Per unit
Sl. Particulars Amount Amount
Quantum Rate Quantum Rate
(in Rs. (in Rs.
(in MU) (Rs/ (in MU) (Rs/
Crore) Crore)
kWh) kWh)
Gross Power
Purchase Cost
G 40861.93 15179.15 3.71 40,200.70 15,822.19 3.94
inclusive of
transmission charges
H Adjustments/Revenue from Sale of Surplus Power
Inter-State
16 515.56 0.00 0.00 -
Transmission Losses
17 Sale to Telangana 0.00 0.00 0.00 - - -
18 Sale of Surplus Power 7075.87 3495.48 4.94 3714.17 1921.02 5.17
Sub-total G 7591.43 3495.48 4.60 3714.17 1921.02 5.17
Net Power Purchase
I 33270.49 11683.67 3.51 36,486.53 13901.17 3.81
Cost

9.8 Other heads of ARR


CSPDCL Submission
In its Petition, CSPDCL has revised all the other components of ARR also for
FY 2023-24.
The summary of other heads of ARR for FY 2023-24 as submitted by CSPDCL in the
Petition are as shown in the table below:
Table 9-9: Other Components of ARR as claimed by CSPDCL for FY 2023-24
SI. No. Particulars CSPDCL Petition
A Operation & Maintenance Expenses 2,447.88
1 Net Employee Expenses 1,317.28
2 Net A&G Expenses 93.38
3 Net R&M charges 268.82
4 Pension & Gratuity 768.40
B Interest & Finance Expenses 533.52
1 Interest on Loan 360.37
2 Interest on Security Deposit -
3 Interest on Working Capital Requirement 173.15
C Other Expenses 984.33
1 Depreciation 531.78
2 Return on Equity 452.55
D Less: Non-Tariff Income 203.97

CSERC Tariff Order FY 2023-24 193


Commission’s View
The Commission has noted that CSPDCL has submitted revised ARR for FY 2023-24
by revising all components of the ARR in the submitted Petition. The Commission
asked CSPDCL the basis and relevant provisions of the MYT Regulations, 2021
under which all the components of the ARR have been revised.
In reply, CSPDCL submitted that it has filed an additional Capital Investment Plan
Petition, which was not envisaged in the Capital Investment Plan filed at the time of
MYT Petition. CSPDCL added that as the additional CIP Petition filed shall impact
the capitalization of CSPDCL during the ensuing years and the same shall impact the
other components of ARR, therefore, CSPDCL has revised all the components of the
ARR.
Regulation 5.7(b)(ii) of the MYT Regulations, 2021 specifies as under:
“(b)After first year of control period and onwards, the yearly true up petition
shall comprise of:

ii. For Distribution Wire and Retail Supply Business
1. The truing up petition for preceding year(s).
2. Revised power purchase quantum/cost (if any), with details thereof for
the ensuing year.
3. Revenue from existing tariffs and charges and projected revenue for
the ensuing year.
4. Application for re-determination of ARR for the ensuing year along-
with retail tariff proposal.”
Thus, in accordance with the MYT Regulations, 2021, only the power purchase cost
component of the ARR can be revised through the present regulatory process, and all
other components of the ARR have to be considered as approved by the Commission
in the MYT Order dated 13 April 2022.
This is also as per the past practice adopted by the Commission. Further, the
Commission has not approved the additional CIP submitted by CSPDCL.
Hence, in order to determine the revised ARR for FY 2023-24, the Commission has
considered the projected sales and power purchase cost for FY 2023-24 as detailed
earlier in this Chapter. The Commission has considered all other components of ARR
as approved in the MYT Order dated 13th April 2022.

9.9 Impact of APTEL Judgement


CSPDCL Submission
CSPDCL has requested the Commission to approve the income on consumer security
deposit amounting to Rs. 30.98 Crore along with carrying cost from FY 2013-14 in
accordance with the decision of the Hon‟ble APTEL in Appeal No. 182 of 2015
against Tariff Order dated 23rd May 2015.

194 CSERC Tariff Order FY 2022-23


Commission’s View
The Hon‟ble APTEL has ruled in favour of CSPDCL in the matter of income on
consumer security deposit, with the principal amounting to Rs. 30.98 Crore, as
claimed by CSPDCL. However, the calculation of carrying cost done by CSPDCL is
incorrect. The Commission has allowed the principal amount of Rs. 30.98 Crore in
FY 2013-14 and has computed the amount with carrying cost up to FY 2023-24 as Rs.
96.24 Crore, as shown in the Table below:
Table 9-10: Impact of APTEL Judgment allowed in FY 2023-24 (Rs. Crore)
Particulars FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23 FY24
Op.
30.98 33.02 37.48 42.54 47.99 54.04 60.63 68.24 76.19 84.49 92.09
Amount
Cl. Amount 30.98 33.02 37.48 42.54 47.99 54.04 60.63 68.24 76.19 84.49 -92.09
Interest
13.20% 13.50% 13.50% 12.80% 12.60% 12.20% 12.55% 11.65% 10.90% 9.00% 9.00%
Rate (%)
Carrying
2.04 4.46 5.06 5.45 6.05 6.59 7.61 7.95 8.30 7.60 4.14
Cosr
Cumulative
33.02 37.48 42.54 47.99 54.04 60.63 68.24 76.19 84.49 92.09 96.24
Amount

9.10 Aggregate Revenue Requirement for FY 2023-24


The summary of the ARR claimed by CSPDCL and the ARR approved by the
Commission for CSPDCL for FY 2023-24 is shown in the Table below:
Table 9-11: Approved ARR for CSPDCL for FY 2023-24 (Rs. Crore)
CSPDCL Approved
Sl. Particulars
Petition
A Power Purchase Expenses* 15,179.15 15,822.19
1 Power Purchase Cost 13,279.30 13,922.34
2 Inter-State Transmission charge 724.69 724.69
3 Intra-State Transmission Charges 1,155.61 1,155.61
4 CSLDC Charges 19.55 19.55
B Operation & Maintenance Expenses 2,447.88 2,430.81
1 Net Employee Expenses 1,317.28 1,308.04
2 Net A&G Expenses 93.38 92.42
3 Net R&M charges 268.82 261.95
4 Pension & Gratuity 768.40 768.40
C Interest & Finance Expenses 533.52 285.01
1 Interest on Loan 360.37 149.52
2 Interest on Security Deposit - -
3 Interest on Working Capital Requirement 173.15 135.49
D Other Expenses 984.33 657.43
1 Depreciation 531.78 296.63
2 Return on Equity 452.55 360.80
E Less: Non-Tariff Income 203.97 185.43

CSERC Tariff Order FY 2023-24 195


CSPDCL Approved
Sl. Particulars
Petition
Impact of APTEL Judgement on CSD 96.24
F 135.71
issue
G Less: Revenue from Sale of Surplus Power 3,495.48 1,877.94
1 Less: Sale of Power to Telangana - -
2 Less: Sale of Surplus Power 3,495.48 1,877.94
H Aggregate Revenue Requirement 15,581.14 17,228.31

9.11 Revenue from sale of power


CSPDCL’s Submission
CSPDCL submitted that the Revenue from Sale of Power for FY 2023-24 has been
calculated based on the tariff approved by the Commission in the Tariff Order for FY
2022-23 dated 13th April, 2022 and the projected sales to each category. CSPDCL
submitted the category-wise revenue from sale of power for FY 2023-24 at existing
tariff as shown in the Table below:
Table 9-12: Revenue from sale of power at existing tariff for FY 2023-24 as
submitted by CSPDCL (Rs. Crore)
Sl. Category
Category Revenue
Name
LV Categories (A) 9,878.29
1 LV 1 Domestic Including BPL Consumers 3,774
2 LV 2 Non-Domestic (Normal Tariff) 204
3 LV 2.1 Non-Domestic (Demand Based) 871
4 LV 3 Agriculture Metered 2,990
5 LV 4 Agriculture allied 29
6 LV 5 LT Industry 584
7 LV 6 Public Utilities 395
8 LV 7 IT & Textile Industries 1
9 LV 8 Temporary 1,031
HV Categories (B) 9,465.88
10 HV 1 Railway Traction 809
11 HV 2 Mines (Coal & Others) 684
Other Industry & General Purpose Non-
12 HV 3 1,846
Industrial
13 HV 4 Steel Industries 5,734
14 HV 5 PWW, Irrigation & Agriculture allied 206
15 HV 6 Residential Purpose 144
16 HV 7 Start-up Power Tariff 36
Industries related to manufacturing of RE
17 HV 8 2
power generation equipment
18 HV 9 IT & Textile Industries 4
19 HV 10 Temporary -
Total (A + B) 19,344.17

196 CSERC Tariff Order FY 2022-23


Commission’s View
The Commission observed that CSPDCL had not correctly computed the revenue
from sale of power to different categories at existing tariff. As a result, the revenue
from existing tariff had been over-estimated by CSPDCL. The Commission, in its
queries, asked CSPDCL to submit the revised revenue from sale of power to different
categories at existing tariff, after addressing the following issues:
 The impact of the Load Factor rebate to HV-1 Railways category and HV-4
Steel category is to be factored in the revenue for the respective category;
 The impact of Time of Day (ToD) tariff applicable to HV-2, HV-3 and HV-4
category is to be factored in the revenue for the respective category;
In reply, CSPDCL submitted revised revenue from existing tariff as Rs. 18,070.56
Crore, thereby showing reduced revenue to the extent of Rs. 1,273.61 Crore. Though
CSPDCL has revised the Revenue in its replies, CSPDCL has not modified the
consequential Revenue Gap/(Surplus) for FY 2023-24, hence, for comparison
purposes, CSPDCL Petition values are being considered, in order to avoid confusion.
The Commission has computed the revenue from sale of power at the prevailing
tariffs approved in the Tariff Order dated 13th April, 2022 and the sales approved for
each category in this Order. The revenue from sale of power for FY 2023-24 at
existing tariff, considering the higher sales projected by the Commission, works out to
Rs. 19,032.47 Crore, as shown in the Table below:
Table 9-13: Revenue from sale of power at existing tariff for FY 2023-24 as
computed by the Commission (Rs. Crore)
Sl. Category
Category Revenue
Name
LV Categories (A) 9986.07
1 LV 1 Domestic Including BPL Consumers 3797.13
2 LV 2 Non-Domestic (Normal Tariff) 257.39
3 LV 2.1 Non-Domestic (Demand Based) 908.16
4 LV 3 Agriculture Metered 3060.66
5 LV 4 Agriculture allied 27.35
6 LV 5 LT Industry 544.03
7 LV 6 Public Utilities 423.68
8 LV 7 IT & Textile Industries 0.83
9 LV 8 Temporary 966.84
HV Categories (B) 9046.39
10 HV 1 Railway Traction 685.11
11 HV 2 Mines (Coal & Others) 645.97
Other Industry & General Purpose Non-
12 HV 3 2065.67
Industrial
13 HV 4 Steel Industries 5283.11
14 HV 5 PWW, Irrigation & Agriculture allied 192.95
15 HV 6 Residential Purpose 143.42
16 HV 7 Start-up Power Tariff 26.29

CSERC Tariff Order FY 2023-24 197


Sl. Category
Category Revenue
Name
Industries related to manufacturing of RE
17 HV 8 2.38
power generation equipment
18 HV 9 IT & Textile Industries 1.48
19 HV 10 Temporary
Total (A + B) 19032.47

9.12 Stand-alone Revenue Gap/(Surplus) for FY 2023-24


CSPDCL’s Submission
CSPDCL submitted that there would be a Revenue Surplus of Rs. 3763.03 crore in
FY 2023-24 on a standalone basis, based on the projected ARR and revenue from
existing tariffs.

Commission’s View
The Commission has computed the standalone Revenue Surplus for FY 2023-24
based on the ARR approved and Revenue from existing tariff as computed earlier, as
shown in the Table below:
Table 9-14: Standalone Revenue Gap/(Surplus) for FY 2023-24 (Rs. Crore)
CSPSCL Approved
Particulars
Petition
Aggregate Revenue Requirement 15,581.14 17,228.31
Revenue from sale of power at existing tariff 19,344.17 19,032.47
Standalone Revenue Gap/(Surplus) for FY 2022-23 (3,763.03) (1,804.16)

The Commission approves standalone Revenue Surplus of Rs. 1,804.16 Crore for
FY 2023-24 for CSPDCL.

9.13 Cumulative Revenue Gap/(Surplus) for FY 2023-24


CSPDCL’s Submission
CSPDCL submitted that there is net standalone Revenue Surplus of Rs. 3763.03 Crore
for FY 2023-24. However, considering the net Revenue Gap of Rs. 6134.77 Crore
carried forward from true up along with carrying cost, there is overall Revenue Gap of
Rs. 2371.73 Crore for FY 2023-24 as shown in the Table below:
Table 9-15: Cumulative Revenue Gap/(Surplus) for CSPDCL for FY 2023-24 as
submitted by CSPDCL (Rs. Crore)
Sr. No. Particulars Petition
1 Aggregate Revenue Requirement (A) 15,581.14
2 Income from sale of Power at Existing Tariff (B) 19,344.17
3 Standalone Revenue Gap/(Surplus) (C=A-B) (3,763.03)

198 CSERC Tariff Order FY 2022-23


Sr. No. Particulars Petition
Gap/(Surplus) from true-up of FY 2021-22
4 6,134.77
including Review Petition
5 Cumulative Revenue Gap/(Surplus) 2,371.73

CSPDCL requested the Commission to approve the net Revenue Gap after
considering surplus/deficit position of CSPGCL/CSPTCL/CSLDC.

Commission’s View
The standalone Revenue Surplus of CSPDCL for FY 2023-24 has been combined
with the Revenue Gap/(Surplus) of CSPGCL, CSPTCL, CSLDC, and CSPDCL after
truing up for FY 2021-22 and the impact of the Review Petition filed by CSPDCL on
the Tariff Order for FY 2022-23, along with carrying cost, as discussed earlier.
Further, it is observed that there is an unadjusted RPO provisioning amount of Rs. 123
Crore, that has been allowed in the ARR of the earlier years. The Commission has
adjusted the above amount of excess provisioning along with carrying cost, which
works out to Rs. 179.50 Crore.
The cumulative Revenue Gap/(Surplus) approved by the Commission for CSPDCL
for FY 2023-24, after considering all the above Revenue Gap/(Surplus) of CSPDCL,
CSPGCL, CSPTCL, and SLDC, is given in the table below:
Table 9-16: Cumulative Revenue Gap/(Surplus) for CSPDCL for FY 2023-24 as
approved by the Commission (Rs. Crore)
Sr. CSPDCL
Particulars Approved
No. Petition
1 Aggregate Revenue Requirement for FY 2023-24 15,581.14 17,228.31
2 Income from sale of power at existing tariff 19,344.17 19,032.47
3 Standalone Revenue Gap/(Surplus) (3,763.03) (1,804.16)
4 Gap/(Surplus) carried forward from final true-up of
- 538.04
FY 2021-22 for CSPGCL
5 Gap/(Surplus) carried forward from final true-up of
- 51.24
FY 2021-22 for CSPTCL
6 Gap/(Surplus) carried forward from final true-up of
- (2.55)
FY 2021-22 for CSLDC
7 Gap/(Surplus) carried forward from final true-up of
FY 2021-22 for CSPDCL, including impact of 6,134.77 4,321.46
Review Petition
8 Reduce excess provisioning for RPO in FY 2016-
(179.50)
17 & FY 2017-18 with carrying cost
9 Cumulative Revenue Gap/(Surplus) 2371.73 2,924.53
10 Adjusted ARR for Recovery 17,952.87 20,152.84
11 Total estimated sales (MU) 28,885 30,635
13 Stand alone cost of supply 5.39 5.62
14 Adjusted Cost of supply after considering Gap 6.22 6.58

CSERC Tariff Order FY 2023-24 199


10 TARIFF PRINCIPLES AND TARIFF DESIGN
10.1 Approach for Tariff for FY 2023-24
The primary objective of the Commission is to protect the interest of the consumer
and at the same time ensuring recovery of reasonable and justified cost by the utilities.
The Commission in the previous Orders as well as this Order has taken various steps
to protect public interest and provided relief to the consumers and Utilities in the State
of Chhattisgarh.
Based on the ARR and Sales approved, the Average Cost of Supply (ACoS) approved
by the Commission for FY 2023-24 is shown in the Table below:
Table 10-1: Average Cost of Supply (Rs./kWh) for CSPDCL for FY 2023-24
Sr. CSPDCL
Particulars Approved
No. Petition
1 Aggregate Revenue Requirement for FY 2023-24 15,581.14 17,228.31
2 Income from sale of power at existing tariff 19,344.17 19,032.47
3 Standalone Revenue Gap/(Surplus) (3,763.03) (1,804.16)
4 Gap/(Surplus) carried forward from final true-up of
- 538.04
FY 2021-22 for CSPGCL
5 Gap/(Surplus) carried forward from final true-up of
- 51.24
FY 2021-22 for CSPTCL
6 Gap/(Surplus) carried forward from final true-up of
- (2.55)
FY 2021-22 for CSLDC
7 Gap/(Surplus) carried forward from final true-up of
FY 2021-22 for CSPDCL, including impact of 6,134.77 4,321.46
Review Petition
8 Reduce excess provisioning for RPO in FY 2016-
(179.50)
17 & FY 2017-18 with carrying cost
9 Total Past Revenue Gap/(Surplus) 6,134.77 4,728.69
10 Cumulative Revenue Gap/(Surplus) 2371.73 2,924.53
11 Adjusted ARR for Recovery 17,952.87 20,152.84
12 Total estimated sales 28,885 30,635.00
12 Stand alone cost of supply 5.39 5.62
13 Adjusted Cost of supply after considering Gap 6.22 6.58
The Commission has not created any regulatory Assets for FY 2022-23.

10.2 Voltage-wise Cost of Supply for FY 2023-24


The Commission has computed the Voltage-wise Cost of Supply (VCoS) for FY
2023-24 as per the methodology adopted in the Tariff Order for FY 2018-19, after
taking into account the ruling of the Hon'ble APTEL in its Judgment dated March 24,
2015 in Appeal No. 103 of 2012, on the issue of determination of tariff and cross-
subsidy with reference to the VCoS.

200 CSERC Tariff Order FY 2022-23


The Commission notes that at present, the voltage-wise losses available are based on
certain assumptions. The actual voltage-wise losses would be available only after the
studies carried out by CSPDCL. In view of the above, the Commission determines the
VCoS on the basis of available data.
Further, the framework prescribed by the Hon'ble APTEL requires that the category-
wise tariffs be determined on the basis of ACoS as well as VCoS, and also the tariffs
for all categories should be within ±20% of the overall ACoS for the Distribution
Licensee. The Commission feels that in the absence of a realistic assessment of the
voltage-wise losses, the determination of VCoS may lead to incorrect conclusions.
However, the Hon'ble APTEL has directed that the tariffs and cross-subsidies have to
be determined keeping in view the VCoS, while ensuring that the tariffs are within
+20% of ACoS. Further, there is no denying that the cost of supply at higher voltages,
i.e., 220 kV, 132 kV, etc., will be lower than the cost of supply at lower voltages, i.e.,
LT, 11 kV, etc., on account of the lower distribution losses at higher voltages and
non-utilisation of the assets at lower voltages for supplying electricity to the
consumers at higher voltages.
Hence, in this Order, the Commission has determined category-wise tariffs on the
basis of ACoS, while at the same time ensuring that the tariffs for the consumers
taking supply at higher voltages is lower than that for consumers taking supply at
lower voltages. The gradual movement initiated in previous Order in this regard has
been carried forward in this Order.
The VCoS for FY 2023-24, as calculated by the Commission based on approved ARR
and available data, is given in the Table below:
Table 10-2: VCoS for FY 2023-24 as calculated by Commission
Sr. 11 kV
Particulars EHV 33 kV Total
No. and LV
1 Energy Sales (MU) 7,922.42 17,517.41 25,439.83
2 Distribution Loss (%) 4.85% 19.35% 15.33%
3 Energy input at 33 kV (MU) 8,326.24 21,719.62 30,045.86
Less: Direct Input to Distribution at 33/11 kV
4 97.48 254.29 351.77
(MU)
5 Energy input to Discom level (MU) 8,228.76 21,465.33 29,694.09
6 EHV Sales (MU) 5,194.87
7 Energy requirement for Distribution (MU) 5,194.87 8,228.76 21,465.33 34,888.96
8 Transmission Loss (%) 3.00% 3.00% 3.00%
9 Energy requirement at G<>T Interface (MU) 5,355.53 8,483.26 22,129.21 35,968.00
10 Avg. Power Purchase Cost Rate (Rs. /kWh) 4.40 4.40 4.40
11 Power Purchase Cost (Rs. Cr.) 2,355.88 3,731.75 9,734.56 15,822.19
12 Other Cost (Rs. Cr.) 209.37 331.64 865.11 1,406.12
13 Past Revenue Gaps (Rs. Cr.) 435.45 689.77 1,799.31 2,924.53
14 Total Cost (Rs. Cr.) 3,000.70 4,753.16 12,398.98 20,152.84
15 Energy Sales (MU) 5,194.87 7,922.42 17,517.41 30,634.70
16 Cost of Supply (Rs. /kWh) 5.78 6.00 7.08 6.58

CSERC Tariff Order FY 2023-24 201


10.3 Tariff Philosophy for FY 2023-24
As discussed earlier, the Commission has determined the Cumulative Revenue Gap of
Rs. 2924.53 Crore. In order to bridge this Revenue Gap, the Commission has taken
the following measures for FY 2023-24:
a) The ToD tariffs have been rationalized. The rebate during off-peak hours is
revised to 20% from 35% and additional charges during peak hours have been
retained as 20%.
b) The tariff for 220 kV and 132 kV sub-categories under HV-4 Steel category has
been rationalized, in line with the voltage-wise tariff differential philosophy
adopted for other categories.
c) The discount of 10% on Energy Charges provided for exclusive Oxygen plants
connected up to 33 kV supply voltage under HV-3 category has been
withdrawn.
d) The discount of 25% on Energy Charges provided to Textile industries
including handlooms and powerlooms, Jute industries, and ethanol industries
categories under HV-3 category has been withdrawn.
e) The monthly power-off hours to be considered for computation of load factor of
HV-4 Steel category has been reduced to „Nil‟ hours for industries connected at
220 kV and 132 kV voltage, and reduced to 30 hours for industries connected at
33 kV and 11 kV voltage.
f) “Mixer and/or stone crushers” have been moved to HV-2 (Mines Tariff
Category) from earlier HV-3 (Other Industrial and General Purpose Non-
Industrial Tariff) Category.
g) The discount on Energy Charges applicable for private clinics, hospitals and
nursing homes including X-ray plant, diagnostic centres and pathological labs,
situated in rural areas as defined by Government of Chhattisgarh and all areas in
Bastar avem Dakshin Kshetra Adivasi Vikas Pradhikaran, and Sarguja avem
Uttar Kshetra Adivasi Vikas Pradhikaran Notified Vide Order dated August 22,
2005, under LV-2 and HV-3 categories has been reduced from 7% to 5%.
h) The discount on Energy Charges applicable for HV-4 Steel industries situated in
Bastar avem Dakshin Kshetra Adivasi Vikas Pradhikaran and Sarguja avem
Uttar Kshetra Adivasi Vikas Pradhikaran has been reduced from 7% to 5%.
Based on the above-elaborated tariff rationalisation measures, it is estimated that
CSPDCL will earn additional revenue in FY 2023-24. However, even after
considering the additional revenue from these tariff rationalisation measures, it is
estimated that revenue deficit of around Rs. 2528 Crore for FY 2023-24 will remain
unmet.
Further, it may be noted that the quantum of unmet revenue requirement for FY 2023-
24 is only an estimate at this stage, and the actual revenue deficit/(surplus), if any,
shall be addressed at the time of true-up for FY 2023-24.
The standalone ACOS for FY 2023-24 has been estimated as Rs. 5.62/kWh. The
adjusted ACoS for FY 2023-24 has been estimated as Rs. 6.58/kWh. The Average
Billing Rate (ABR) for FY 2023-24 with existing tariffs is estimated to be
Rs. 6.21/kWh. Considering the tariff rationalisation measures, the estimated ABR for

202 CSERC Tariff Order FY 2022-23


FY 2023-24 works out as Rs. 6.34/kWh which is higher than the ABR with the
existing tariff, i.e., Rs. 6.21/kWh with prevailing terms and conditions of tariff. The
ABR for FY 2023-24 is significantly higher than the standalone ACOS of FY 2023-
24, thereby indicating that the expenses of FY 2023-24 will be met, and the shortfall
would be only in meeting the revenue deficit due to true-up of FY 2021-22.
Further, it may be noted that the quantum of unmet revenue requirement for FY 2023-
24 is only an estimate at this stage, and the actual revenue deficit/(surplus), if any,
shall be addressed at the time of true-up for FY 2023-24.
The Commission has increased the Energy Charges only for HV Steel industries
category that too only for 220 kV and 132 kV sub category by 25 paise/kWh for both
with no change being made in the Fixed/Demand Charges.

10.4 Power Factor Incentive and Surcharge for LV category


The Commission has retained the Power Factor Incentive and Surcharge as approved
in the previous Tariff Order for FY 2022-23, wherein, in order to improve the overall
Power Factor, the Commission has retained floor level of Power Factor of 0.90, below
which Power Factor surcharge shall be applicable on the entire consumption of the
month at the rate of 35 paise/kWh or 75 paise/kWh as per existing dispensation.
Further, Power Factor incentive for Power Factor above 0.95 is retained for all
categories of LV consumers in whose case power factor surcharge is applicable. Such
incentive is payable @ 1% of the energy charges for each 0.01 increase or part thereof
in power factor above 0.95 up to unity power factor. For example, consumers with
Power Factor of 0.965 shall be considered as 0.97 and be eligible for power factor
incentive of 2% of energy charges. Consumers with Power Factor of 0.964 shall be
considered as 0.96 and be eligible for power factor incentive of 1% of energy charges.

10.5 Method of payment of Bills


The consumers shall have the option to pay bills online or offline. However, bill
amounts of more than five thousand rupees shall mandatorily be paid online.
For bill amount less than or equal to five thousand rupees, consumer may pay the bill
through cash or cheque or demand draft or electronic clearing system at designated
counters of a bank or through credit or debit cards or online payment through
distribution licensees‟ web portal or any digital mode of payment and any change or
further addition in the mode of payment shall be more user friendly for the consumers
than the prevailing system. Further, the distribution licensee may stipulate a suitable
incentive or rebate for payment through online system for consumers who opt to pay
bill amount less than or equal to five thousand rupees.
The distribution licensee shall establish online portal as well as sufficient number of
collection centres or drop boxes at suitable locations with necessary facilities, where
consumer can deposit the bill amount with ease.

10.6 Billing on accumulated meter reading


The Commission has retained the dispensation related to billing on accumulated meter
reading, as approved in the previous Tariff Order, as under:

CSERC Tariff Order FY 2023-24 203


In order to alleviate the difficulties related to billing based on accumulated meter
reading and to improve the accountability of CSPDCL‟s officers, henceforth, if the
bills are not issued consecutively for three months or more for any LT Consumer,
billing on accumulated meter reading shall not be raised without approval of
concerned Executive Engineer of CSPDCL.

10.7 Category-wise tariff


The approach of the Commission for determination of tariff for FY 2023-24 for
various consumer categories is discussed below.

10.7.1 LV 1: Domestic
The applicability and tariff of this category has been retained as approved in the
previous Tariff Order for FY 2022-23.
At present, tariff for this category is telescopic in nature with five consumption slabs.
It is settled practice to subsidise the low-income groups through intra-category cross-
subsidy mechanism. Similar approach has been taken for FY 2023-24. The
Commission has retained the slabs for fixed charges and energy charges as approved
in the Tariff Order for FY 2022-23.
The energy charges of all consumption slabs have been retained as approved in the
previous Tariff Order for FY 2022-23. Both energy charges and fixed charges have
been kept telescopic, which will enable the consumers in higher consumption slabs to
also get the benefit of the lower energy charges in the lower consumption slabs and
lower fixed charges in the lower slabs. Further, Domestic consumers shall be entitled
for subsidy as per State Government Order, and their consumption shall be billed as
per tariff LV-1.
Based on the above, the monthly minimum charges are now same as the fixed charges
on Rs/kW/month.
Further, if the Recorded Demand exceeds the Connected Load for any three
consecutive months, then the Connected Load shall automatically be restated to the
highest demand recorded in these three months. In such cases of upward restatement
of Connected Load, the load enhancement charges shall be applicable; however, the
Security Deposit shall not be required to be increased correspondingly.
Also, if the Recorded Demand is lower than the Connected Load for any three
consecutive months, then the Connected Load can be restated to the highest demand
recorded in these three months at the option of the consumer.

10.7.2 LV 2: Non-Domestic
The load limit for single-phase connection for LV 2 category has been retained as 5
kW.
A new sub-category “Saw mill with carpenters and furniture makers” has been
introduced and included in LV-2: Non-Domestic Tariff Category.
Non-Domestic tariff category has two sub-categories, i.e., consumption-based and
demand-based, which has been retained.
The Energy Charges for all sub-categories and consumption slabs have been retained
as approved in the previous Tariff Order for FY 2022-23.
204 CSERC Tariff Order FY 2022-23
The Commission has continued with 50% rebate in energy charges for new mobile
towers, to be set up in remote left-wing extremism affected districts after April 1,
2021.
Further, the Commission has continued with flat rate single part Tariff for charging
stations of electric vehicles at Rs. 5/kWh.
The discount of 10% on Energy Charges for commercial activities being run
exclusively by registered women self-help groups has been retained.
The Commission has rationalized the discount from 7% to 5% on Energy Charges
applicable for private clinics, hospitals and nursing homes including X-ray plant,
diagnostic centres and pathological labs, situated in rural areas as defined by
Government of Chhattisgarh and all areas in Bastar avem Dakshin Kshetra Adivasi
Vikas Pradhikaran, and Sarguja avem Uttar Kshetra Adivasi Vikas Pradhikaran
Notified Vide Order dated August 22, 2005.
Further, if the Recorded Demand exceeds the Connected Load for any three
consecutive months, then the Connected Load shall automatically be restated to the
highest demand recorded in these three months. In such cases of upward restatement
of Connected Load, the load enhancement charges shall be applicable; however, the
Security Deposit shall not be required to be increased correspondingly.
Also, if the Recorded Demand is lower than the Connected Load for any three
consecutive months, then the Connected Load can be restated to the highest demand
recorded in these three months at the option of the consumer.

10.7.3 LV 3: Agriculture
Consumers opting for flat rate billing under KJJY scheme shall pay Rs.
100/HP/month as flat rate charges; in addition to fixed charges on billing demand plus
energy charges on consumption payable by State Government under KJJY scheme up
to the applicable ceiling limit of 6000/7500 units annual consumption.
The concession of 20% provided to the consumers having second pump, which does
not receive Government Subsidy, has been retained.

10.7.4 LV 4: Agriculture Allied Activities


The applicability and tariff of this category has been retained as approved in the
previous Tariff Order for FY 2022-23.

10.7.5 LV 5: LT Industries
The Commission has included “Mines with stone crusher unit” and “Mixer and/or
stone crushers” in LV-5: L.V. Industry Tariff Category.
A discount of 5% on Energy Charges for Poha and Murmura mills under LV-5
category is retained.
The lower tariff fixed for consumers located in the areas covered under "Bastar avem
Dakshin Kshetra Adivasi Vikas Pradhikaran" and "Sarguja avem Uttar Kshetra
Adivasi Vikas Pradhikaran"(both notified vide Order dated August 22, 2005) has been
retained. The Commission has continued with the rebate of 5% in energy charges for
LT industries located in rural areas. In order to promote Women Empowerment, the

CSERC Tariff Order FY 2023-24 205


Commission has continued with 10% rebate on energy charges for industrial activities
being run exclusively by registered women self-help groups.

10.7.6 LV 6: Public Utilities


The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23.

10.7.7 LV 7: IT Industries & Export Oriented Textiles


The Commission has retained the applicability and tariff of this category as approved
in previous Tariff Order.

10.7.8 LV 7: Temporary Supply


The Tariff structure for temporary supply has been retained as determined in previous
Orders, i.e., Fixed Charge and Energy Charge shall be billed at one and half times the
normal tariff as applicable to the corresponding consumer categories.
The Commission‟s approach for determination of tariff for FY 2023-24 for HV
categories is discussed below:

10.7.9 HV 1: Railway Traction


In order to give impetus to electrification of railway network in the State, a rebate of
10% in energy charges for new railway traction projects is being allowed for a period
of five years from the date of connection for such new projects for which Agreements
for availing supply from the Licensee have been finalised during FY 2018-19.
Load factor rebate to traction load of Indian Railways, has been retained i.e. if Load
Factor for any month is above 20%, then a rebate of 20% shall be allowed on Energy
Charge calculated on entire energy consumption for that month.

10.7.10 HV 2: Mines
The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23. The Commission has included “Mixer and/or stone crushers” loads in
HV-2 (Mines Tariff Category) which was earlier in HV-3 (Other Industrial and
General Purpose NonIndustrial Tariff) Category.

10.7.11 HV 3: Other Industrial and General Purpose Non-Industrial


The Commission has shifted “Mixer and/or stone crushers” category from HV-3
(Other Industrial and General Purpose Non-Industrial Tariff) Category to HV-2
(Mines Tariff Category).
Special flat rate single-part tariff is continued for Electric Vehicle charging stations.
The discount of 5% on Energy Charges applicable for private clinics, hospitals and
nursing homes including X-ray plant, diagnostic centres and pathological labs,
situated in rural areas as defined by Government of Chhattisgarh and all areas in
Bastar avem Dakshin Kshetra Adivasi Vikas Pradhikaran, and Sarguja avem Uttar
Kshetra Adivasi Vikas Pradhikaran Notified Vide Order dated August 22, 2005, has
been continued.

206 CSERC Tariff Order FY 2022-23


The discount of 15% on Energy Charges applicable for defence establishments under
Government of India has been continued.
The discount of 5% on Energy Charges applicable for rice mills/Poha and murmura
mills has been continued.
The discount of 10% on Energy Charges provided for exclusive Oxygen plants
connected up to 33 kV supply voltage under HV-3 category has been withdrawn.

The discount of 25% on Energy Charges provided to Textile industries including


handlooms and powerlooms, Jute industries, and ethanol industries categories under
HV-3 category has been withdrawn.

10.7.12 HV 4: Steel Industries


The Energy Charges for 220 kV and 132 kV sub-categories have been increased by 25
paise/kWh, while the Energy Charges for 33 kV and 11 kV sub-categories have been
retained as approved in the previous Tariff Order for FY 2022-23.
The Commission had retained the Load Factor rebate as provided in the Tariff Order
for FY 2022-23.
The monthly power-off hours to be considered for computation of load factor of HV-4
Steel category has been reduced to „Nil‟ hours for industries connected at 220 kV and
132 kV voltage, and reduced to 30 hours for industries connected at 33 kV and 11 kV
voltage.
The Licensee and consumers shall ensure compliance with all safety requirements
specified under the applicable laws and amendments thereof from time to time.
Further, rebate provided for industrialization in the areas covered under "Bastar avem
Dakshin Kshetra Adivasi Vikas Pradhikaran" (notified vide Order dated August 22,
2005) and "Sarguja avem Uttar Kshetra Adivasi Vikas Pradhikaran" (notified vide
Order dated August 22, 2005), has been rationalised to 5% on energy charge which is
being provided to the consumers starting production on or after April 1, 2017.

10.7.13 HV 5: Irrigation, Agriculture Allied Activities & Public Water Works


The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23.

10.7.14 HV 6: Residential
The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23.

10.7.15 HV 7: Start up Power


The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23. The generators and captive generating plants who have not availed start
up connection and eventually draw power are not required to be billed separate
demand charges. The rate for such industries which eventually draws power has been
prescribed at @ Rs. 12 per kVAh and this rate factors in the demand charges and the

CSERC Tariff Order FY 2023-24 207


energy charges both. This was the spirit behind prescribing this rate in previous tariff
orders and the same has been continued without any change.

10.7.16 HV 8: Industries related to manufacturing of equipment for power generation


from renewable energy sources
The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23.

10.7.17 HV 9: Information Technology & Export Oriented Textile Industries


The energy charges have been retained as approved in the previous Tariff Order for
FY 2022-23.

10.7.18 HV 10: Temporary Connection at HV


The Tariff structure for temporary supply has been retained as determined in previous
Orders, i.e., Fixed Charge and Energy Charge shall be billed at one and half times the
normal tariff as applicable to the corresponding consumer categories.

10.8 Minimum Billing Demand


The minimum Billing Demand for the relevant LV categories and all HV categories
has been retained at 80% level.

10.9 Time of Day Charges


The ToD time-slots have been retained as approved in the previous Tariff Order but
rate of Off-peak load period (11.00 p.m. to 05.00 a.m. of next day.) has been changed
from 65% to 80% of normal rate of energy charge and for other slot the rates are
retained as approved in the previous Tariff Order.

10.10 Wheeling Charges


The Wheeling Charges have been computed by considering 35% of the Wires ARR,
in line with the approach adopted in previous Tariff Orders. The total energy
requirement at 33 kV has been considered as 29694.09MU based on the approved
Energy Balance for FY 2023-24.
For long-term, medium-term and short-term open access customers, Wheeling
Charges shall be Rs. 282.70/MWh (or Rs. 0.2827 per kWh) for the energy computed
as per the provisions made in Regulation 33 of the CSERC (Connectivity and Intra
State Open access) Regulations, 2011 and its subsequent amendment(s)/revision, if
any, at 100% load factor for wheeling. The same charges shall be applicable for both
collective and bilateral transactions at the point of injection.
Energy losses shall be applicable at the rate of 6% for the energy scheduled for
distribution at the point or points of injection at 33 kV side of 33/11 kV sub-station.
For Renewable Energy Open Access transactions:
a) The Open Access customers availing long-term/medium-term/short-term open
access customers shall bear the energy loss specified as under:
a. Energy Losses for using only the Transmission system of CSPTCL shall
be 3%.

208 CSERC Tariff Order FY 2022-23


b. Energy Losses/for using only distribution system of CSPDCL shall be 6%.
c. Energy losses for using both the transmission system of CSPTCL and
distribution system of CSPDCL or Combination thereof shall be 6%.

10.11 Revenue at Approved Tariff


The approved Tariff Schedule is given in the next Chapter.
The revised tariff will be applicable with effect from April 1, 2023, for the consumers
of the State, for FY 2023-24. The category-wise revenue at revised tariffs approved in
this Order is shown in the Table below:
Table 10-3: Revenue in FY 2023-24 at Tariffs approved by the Commission

Sl. Category
Category Revenue
Name
LV Categories (A) 9986.07
1 LV 1 Domestic Including BPL Consumers 3797.13
2 LV 2 Non-Domestic (Normal Tariff) 257.39
3 LV 2.1 Non-Domestic (Demand Based) 908.16
4 LV 3 Agriculture Metered 3060.66
5 LV 4 Agriculture allied 27.35
6 LV 5 LT Industry 544.03
7 LV 6 Public Utilities 423.68
8 LV 7 IT & Textile Industries 0.83
9 LV 8 Temporary 966.84
HV Categories (B) 9442.42
10 HV 1 Railway Traction 685.11
11 HV 2 Mines (Coal & Others) 667.93
Other Industry & General Purpose Non-
12 HV 3 2129.37
Industrial
13 HV 4 Steel Industries 5593.48
14 HV 5 PWW, Irrigation & Agriculture allied 192.95
15 HV 6 Residential Purpose 143.42
16 HV 7 Start-up Power Tariff 26.29
Industries related to manufacturing of RE
17 HV 8 2.38
power generation equipment
18 HV 9 IT & Textile Industries 1.48
19 HV 10 Temporary
Total (A + B) 19428.50

The computation of category-wise revenue from revised tariff approved for CSPDCL
for FY 2023-24 is given as Annexure V to this Order.
CSERC Tariff Order FY 2023-24 209
10.12 Cross-subsidy
An element of cross-subsidy is inherent in the present and revised tariff structure. The
tariffs of different consumer categories in relation to the approved adjusted ACoS of
Rs. 6.58 per kWh is such that the tariffs for some categories of consumers are higher
than the ACoS while the tariffs for other categories are lower than the ACoS. The
Commission has rationalised the cross-subsidy in this Order as shown in the Table
below:
Table 10-4: Cross-subsidy with Existing tariff and Approved tariff
Approved in Tariff Approved in Tariff
Order FY 2022-23 Order for FY 2023-24
Consumer Category
ABR (Rs. ABR/ ABR (Rs. ABR/
/kWh) ACOS (%) /kWh) ACOS (%)
Domestic 5.13 82% 5.22 79%
Non-Domestic 8.97 144% 9.06 138%
L
Agriculture 5.43 87% 5.45 83%
V
Industry 7.67 123% 7.56 115%
Public Utilities 6.93 111% 6.94 106%
Railway Traction 5.33 86% 5.25 80%
Mines 9.02 145% 9.21 140%
H
V Other Industrial & General
9.17 147% 9.15 139%
Purpose Non-Industrial
Steel Industries 6.36 102% 6.21 94%

10.13 Cross-Subsidy Surcharge


The Commission has determined the Cross-Subsidy Surcharge (CSS) to be paid by
the Open Access consumers, in accordance with CSERC (Connectivity and Intra-
State Open Access) Regulations, 2011:
The approved Cross-Subsidy Surcharge is as under:
Rs. 1.28 per kWh for 220 kV/132 kV consumers (which is 90% of the computed
value of Rs. 1.43 per kWh)
Rs. 2.35 per kWh for 33 kV consumers (which is 90% of the computed value of Rs.
2.61 per kWh).
For Open Access consumers procuring power from Renewable Energy based power
generating plant (excluding solar power), the Cross-Subsidy Surcharge payable shall
be 50% of the Cross-Subsidy Surcharge determined for that year.
Accordingly, Cross-subsidy Surcharge for Renewable Energy transactions is as under:
(a) For 220 kV/132 kV consumers - Rs.0.64 per kWh (which is 50% of the CSS
applicable for other 220 kV/132 kV consumers).
(b) For 33 kV consumers - Rs. 1.17 per kWh (which is 50% of the CSS applicable for
other 33 kV consumers).

210 CSERC Tariff Order FY 2022-23


In case of a consumer receiving power from Solar power plants through open access,
Cross Subsidy Surcharge shall be applicable as per the provisions of CSERC (Grid
Interactive Distributed Renewable Energy Sources) Regulations, 2019, as amended
from time to time and Orders thereunder.

10.14 Fuel and Power Purchase Adjustment Surcharge (FPPAS)


The Commission is likely to introduce the Fuel and Power Purchase Adjustment
Surcharge (FPPAS) formula consistent with the Electricity (Amendment) Rules,
2022, notified by Central Govt., which may be made effective from April 1, 2023.
FPPAS shall be levied on the energy charges on all the LV and HV categories
including temporary supply. The FPPAS amount for CSPDCL shall be determined on
monthly basis.
Unless intimated otherwise by the Commission, FPPAS shall be computed and
charged by CSPDCL, in (n+2)th month, on the basis of actual variation, in cost of fuel
and power purchase and Inter-State Transmission Charges for the power procured
during the nth month. The percentage and the amount of the FPPAS shall be shown
separately in the consumers' bills. For example, the fuel and power purchase
adjustment surcharge on account of changes in tariff for power supplied during the
month of April of any financial year shall be computed and billed in the month of
June of the same financial year.
CSPDCL shall work out the amount of FPPAS and shall intimate the same and
manner of determination of the same to the Commission. The gist of FPPAS
computation shall be widely publicized by CSPDCL in the leading newspapers of the
State. Calculations of the FPPAS for the particular month shall be displayed by
CSPDCL on its website for the information of the consumers.
The new FPPAS formula is likely to be implemented from 1st April 2023. Amount on
account of variations in actual Energy Charge is to be claimed by CSPGCL as a line
item namely fuel and other expenses through regular monthly energy bills instead of
bimonthly basis envisaged earlier. The variation in energy charge due to change in
landed price of coal and GCV as received during the month of April 2023 shall be
recoverable in energy bill raised for the period of June 2023 and so on. Format for the
calculation are enclosed as Annexure-IV.
In order to avoid simultaneous recovery of FCA in accordance to previous tariff order
and variation in energy charge in accordance to aforesaid amendment, Generation
company shall not claim FCA amount for the bi-monthly period February 2023 to
March 2023 in the energy bill, instead the same shall be claimed during annual true-
up of the year.
Further, as per the new formula, the change in power purchase cost for the month of
April 2023 is to be recovered through FPPAS in the month of June 2023. Therefore,
VCA for the month January, February and March 2023 which is scheduled to be
recovered in the month of June, July and August 2023 respectively, should not be
recovered from the consumer. The under recovery on account of change in VCA for
month of January, February and March 2023 shall be taken care during truing up of
FY 2022-23.

CSERC Tariff Order FY 2023-24 211


The values of various parameters required for calculation of FPPAS are given below:

i. Average Billing Rate (ABR) – Rs. 6.34/ kWh


ii. Intra-State Losses – 3%
iii. Distribution Losses – 13.07%
iv. Inter-State Losses – 3.43%
v. Projected average Power Purchase Cost (PPC) – Rs. 3.46/kWh

10.15 Parallel Operation Charges


The Commission has retained the Parallel Operation Charges (POC) as 13 paise/kWh
as determined in the previous Tariff Order.

10.16 Applicability of Order


The approved Tariff Schedule for FY 2023-24 is given in the next Chapter.
The Order will be applicable from 1st April, 2023 and will remain in force till
March 31, 2024 or till the issue of next Tariff Order, whichever is later. The
Commission directs the Companies to take appropriate steps to implement the
Tariff Order.

212 CSERC Tariff Order FY 2022-23


11 TARIFF SCHEDULE FOR FY 2023-24
This Tariff Schedule shall be applicable from April 1, 2023.

11.1 Tariff Schedule for Low Voltage (LV) Consumers


This tariff schedule is applicable to all LV consumers as follows:

a) Single-phase, 230 Volts up to a maximum Sanctioned Load of 5 kW (excluding


agriculture and industrial consumers), and

b) Three-phase, 400 Volts for maximum demand up to 112 kW in case of demand-


based tariff or for maximum Sanctioned load of 150 HP in case of other tariff, as
applicable.

11.1.1 LV-1: Domestic


Applicability
This tariff is applicable to domestic light and fan and power used for all domestic
appliances, in residential premises, orphanages, homes for old/physically challenged
people and homes for destitute, dharamshalas and working women's hostels run by
charitable Trust, Government student hostels, ashrams, offices of National Cadet Core
(NCC), Public Libraries and reading rooms, educational institutions and hospitals
(including X-rays, etc.) run by charitable trusts / non-profit organizations / societies
registered under the Firms and Societies Act, homes for differently abled and
mentally retarded, de-addiction and rehabilitation centres, Government
hospitals/dispensaries, (excluding private clinics and nursing homes), facilities like
prayer hall, gymnasium and club house within the housing society, Government
Schools, farm houses for own use, mosques, temples, churches, gurudwaras, religious
and spiritual institutions, water works and street lights in private colonies and
cooperative societies, common facilities such as lighting in staircase, lifts, fire-
fighting in multi-storied housing complex, light and fan in gauthan and khalihan,
kothar, byra where agriculture produce is kept, post office at residence of a villager,
residential premises of professionals such as advocates, doctors, artists, consultants,
weavers, bidi makers, beauticians, stitching and embroidery workers including their
chambers, public toilets, fractional HP motors used for Shailchak by Kumhars in their
residences, zero waste centre compost unit.

CSERC Tariff Order FY 2023-24 213


Tariff:
Energy
Category of Fixed Charge
Units Slab Charge
Consumers (Rupees per kW)
(Rs. per kWh)
LV-1: Domestic
0 -100 units Rs. 20/- per kW/month for 3.70
Sanctioned Load up to 5 kW;
101-200 units 3.90
Domestic Rs. 30/- per kW/month for
including BPL 201 - 400 units Sanctioned Load above 5 kW 5.30
Consumers 401 – 600 units and up to 10 kW; 6.30
Rs. 40/- per kW per month for
601 and above units Sanctioned Load above 10 kW 7.90

Notes:
i. Energy Charges are telescopic. For example, if consumption in any month is 150
units, then for first 100 units, rate of slab 0-100 shall be applicable and for
remaining 50 units, rate of slab 101-200 shall be applicable;

ii. Fixed Charges is a monthly minimum charge, whether any energy is consumed
during the month or not;

iii. Fixed Charges are telescopic. For example, if Sanctioned Load is 7 kW, then the
rate of Rs. 20/- per kW/month shall be applicable for the first 5 kW and the rate
of Rs. 30/- per kW/month shall be applicable for the balance 2 kW;

iv. If the Recorded Demand exceeds the Sanctioned Load for any three consecutive
months, then the Sanctioned Load shall automatically be restated to the highest
demand recorded in these three months. In such cases of upward restatement of
Sanctioned Load, the load enhancement charges shall be applicable; however, the
Security Deposit shall not be required to be increased correspondingly.
v. If the Recorded Demand is lower than the Sanctioned Load for any three
consecutive months, then the Sanctioned Load can be restated to the highest
demand recorded in these three months at the option of the consumer.

vi. Domestic consumers shall be entitled for subsidy as per State Government Order,
and their consumption shall be billed as per tariff LV-1.

vii. If a portion of the dwelling is used for the conduct of any business other than
those stipulated above, the entire consumption shall be billed under Non-domestic
tariff LV-2.

214 CSERC Tariff Order FY 2022-23


11.1.2 LV-2: Non-Domestic
Applicability
This tariff is applicable to light and fan and power to shops, showrooms, business
houses, offices, educational institutions (except those included in LV-1 and LV-5),
public buildings, Warehouses, town halls, clubs, gymnasium and health clubs,
meeting halls, places of public entertainment, circus, hotels, cinemas, railway
stations, private clinics and nursing homes including X-rays plant, diagnostic centres,
pathological labs, carpenters and furniture makers, saw mill with carpenters and
furniture makers, juice centres, billboards/hoardings and advertisement services,
typing institutes, internet cafes, STD/ISD PCO‟s, Mobile Towers, coaching centres,
FAX/photocopy shops, tailoring shops, photographers and colour labs, laundries,
cycle shops, compressors for filling air, toy making industry, nickel plating on small
scale, restaurants, eating establishments, Government circuit houses/rest houses, guest
houses, marriage gardens, farmhouses being used for commercial purposes, book
binders, offset printers, bakery shop, banks, parlours, printing press, computer centre,
petrol pumps and service stations, electric charging centres for Vehicles, HV
industrial consumers seeking separate independent LV connection in the same
premises of HV industrial connection and other consumers not covered under any
other category of LV consumers.

Tariff:
Fixed Charge (Rs
Energy
Category of per kW of
Units Slab Charge (Rs.
Consumers Contracted
per kWh)
load/Billing Demand)
0 – 100 units Rs. 50 per kW per 5.85
LV-2.1: Single Phase
Non-Domestic- (up to 101 - 400 units month 6.85
5 kW)
401 and above units 8.25
LV-2.2: Three Phase
Non-Domestic
0-400 units Demand Charges- Rs 6.85
(A) Up to 15 kW 120/kW/month on
401 and above units billing demand 8.25

Demand Charges- Rs
(B) Above 15 kW All units 200/kW/month on 7.55
billing demand

CSERC Tariff Order FY 2023-24 215


Notes:
i. Fixed Charges of LV-2.1 and Demand Charge on contract demand of tariff LV-
2.2 is a monthly minimum charge, whether any energy is consumed during the
month or not.
ii. If the Recorded Demand exceeds the Sanctioned Load for any three consecutive
months, then the Sanctioned Load shall automatically be restated to the highest
demand recorded in these three months. In such cases of upward restatement of
Sanctioned Load, the load enhancement charges shall be applicable; however,
the Security Deposit shall not be required to be increased correspondingly.

iii. If the Recorded Demand is lower than the Sanctioned Load for any three
consecutive months, then the Sanctioned Load can be restated to the highest
demand recorded in these three months at the option of the consumer.

iv. For charging stations of electric vehicles, a flat rate single part tariff of Rs. 5 per
unit shall be applicable.
v. The discount of 50% on Energy Charges applicable for mobile towers set up
after 1st April 2021 in left-wing extremism affected districts shall continue.
vi. A discount of 10% on Energy Charges shall be applicable for commercial
activities being run exclusively by registered women self-help groups.
vii. A discount of 5% on Energy Charges shall be applicable for private clinics,
hospitals and nursing homes including X-ray plant, diagnostic centres and
pathological labs, situated in rural areas as defined by Government of
Chhattisgarh and all areas in Bastar avem Dakshin Kshetra Adivasi Vikas
Pradhikaran, and Sarguja avem Uttar Kshetra Adivasi Vikas Pradhikaran
Notified Vide Order dated August 22, 2005.

11.1.3 LV-3: L.V. Agriculture


Applicability
This tariff is applicable to agricultural pumps/tube wells used for irrigation (including
drip and sprinkler system) for crops, nursery, baadi, horticulture crops (growing
vegetables and fruits), floriculture (growing flowers), growing of herbs/medicinal
plants and mushroom, jatropha plantation, chaff cutters, thresher, winnowing
machines, sugarcane crushers used on agricultural land, lift irrigation pumps/tube
wells of State Government or its agencies, water drawn by agriculture pumps used by

216 CSERC Tariff Order FY 2022-23


labour, cattle, and farm houses in the premises of agriculture farms for drinking
purposes only and packaging of agriculture produce at farm, khalihan, etc.

Tariff:
Energy Charge
Category of Consumers Fixed Charge
(Rs. per kWh)
LV-3: Agriculture Rs. 100/HP/month 5.05

The load of 100 W for light and fan is permitted in hutment at or near the motor pump
set.
Notes:
i. Fixed Charge is monthly minimum charge, whether any energy is consumed
during the month or not.
ii. For non-subsidized agriculture pump connection, a concession of 20% on
energy charges shall be allowed.
iii. Consumers opting for flat rate billing under KJJY scheme shall pay Rs.
100/HP/month as flat rate charges; in addition to fixed charges on billing
demand plus energy charges on consumption payable by State Government
under KJJY scheme up to the applicable ceiling limit of 6000/7500 units
annual consumption.

11.1.4 LV- 4: L.V. Agriculture Allied Activities


Applicability
This tariff is applicable to pump/tube well connections, other equipment and light and
fan for tree plantation, fisheries, hatcheries, mushroom cultivation, bee farming,
poultry farms, dairy, cattle breeding farms, sericulture, tissue culture, aquaculture
laboratories and milk chilling plant.

Tariff:
Energy
Category of Consumers Fixed Charge Charge
(Rs. per kWh)
Rs. 100 per HP per month or
LV-4.1 (A): Up to 25 HP 5.05
Rs. 134 per kW per month
LV-4.1 (B):Above 25 HP up to 150 Rs. 110 per HP per month or
5.45
HP Rs. 147 per kW per month
LV-4.2: Demand based tariff for Rs. 200 per kW per month
5.65
Contract Demand of 15 to 112.5 kW on billing demand

CSERC Tariff Order FY 2023-24 217


Note:
Fixed Charge is monthly minimum charge. Demand Charge on contract demand is
monthly minimum charge, whether any energy is consumed during the month or not.

11.1.5 LV-5: L.V. Industry


Applicability
i. These tariffs are applicable to power, light and fan for industries such as flour
mills, hullers, grinders for grinding masala, textile industries including power
looms and handlooms, rice mills, poha and murmura mills, daal-mills, oil mills,
ice factories, cold storage plants, ice candies, terracotta, Jute industries,
handicraft, agro-processing units, minor forest produce, ethanol industries,
laboratories of engineering colleges, ITIs and polytechnics and industrial
institutions, aluminium based factory, bakery/biscuit industries, bottling plant,
cable/insulation industries, Cement Based Factory, Chemical Plant, Coal Based
Industries, Conductor Wire Industries, Cutting & Polishing Of Marble,
Fabrication Workshop, Food Processing Industry, Forest Product based factory,
GI Wire Industries, Glass Industries, Hot Mixing Plant, IT based industries,
Mineral based factory, Plastic Industries, Plywood factory, Pulverize industries,
Rolling Mill, Standalone Saw Mill, mines, mines with stone crusher unit, stone
crusher, mixer, mixer with stone crushers, Toy Industries, Wire Drawing / Steel
Industries, Wire Product, Registered Women self-help group, workshops,
fabrication shop, Gramin Aoudyogik Park established under Narwa, Garua,
Ghurwa, Bari Sankalpana Yojana of the Government of Chhattisgarh, etc.

Tariff:
Energy
Demand Charge
Category of Consumers
Charge (Rs. per
kWh)
LV-5: L.V. Industry
5.1 Flour mills, Hullers, power looms, grinders 4.15
Rs.
for grinding masalas, terracotta, handloom, 80/kW/month
handicraft, agro-processing units, minor forest on billing
produce up to 25 HP or 18.7 kW demand

a) Bastar avem Dakshin Kshetra Adivasi Vikas Rs. 3.75


Pradhikaran, and Sarguja avem Uttar Kshetra 80/kW/month
on billing
Adivasi Vikas Pradhikaran* demand

218 CSERC Tariff Order FY 2022-23


Energy
Demand Charge
Category of Consumers
Charge (Rs. per
kWh)
5.2 Other Industries
5.2.1 Up to 25 HP or 18.7 kW Rs. 5.15
120/kW/month
on billing
demand
a) Bastar avem Dakshin Kshetra Adivasi Vikas Rs. 4.15
Pradhikaran, and Sarguja avem Uttar Kshetra 100/kW/month
Adivasi Vikas Pradhikaran* on billing
demand
5.2.2 Above 25 HP up to 150HP (18.7 kW to 112.5 Rs. 5.90
kW) 150/kW/month
on billing
demand
a) Bastar avem Dakshin Kshetra Adivasi Vikas Rs. 5.40
Pradhikaran, and Sarguja avem Uttar Kshetra 130/kW/month
Adivasi Vikas Pradhikaran* on billing
demand
*Notified Vide Order dated August 22, 2005
Notes:
i. Demand Charge on contract demand is monthly minimum charge, whether any
energy is consumed during the month or not.
ii. In order to give impetus to LT industries located in rural areas, a rebate of 5% in
energy charges for consumers specified under tariff category shall be allowed
for LV industries located in rural areas notified by Government of Chhattisgarh..

iii. In accordance with the Section 62(3) of EA 2003 providing for differentiation in
tariff based on geographical position of any area, considerably lower tariff has
been determined for consumers located in the areas covered under "Bastar
avem Dakshin Kshetra Adivasi Vikas Pradhikaran" (notified vide Order
dated August 22, 2005) and "Sarguja avem Uttar Kshetra Adivasi Vikas
Pradhikaran" (notified vide Order dated August 22, 2005).

iv. A rebate of 10% on Energy Charges shall be applicable for industrial activities
being run exclusively by registered women self-help groups.

v. A discount of 5% on Energy Charges shall be applicable for Poha and Murmura


mills.

CSERC Tariff Order FY 2023-24 219


11.1.6 LV-6: Public Utilities
Applicability
This tariff is applicable to colonies developed by Chhattisgarh State Housing Board
and public utilities such as water supply schemes, sewage treatment plants and
sewage pumping installations, crematorium, traffic signals and lighting of public
streets including public parks and archaeological and other monuments when
requisition for supply is made by Public Health Engineering Department, Local
Bodies, Gram Panchayats or any organization made responsible by the Government to
maintain these services.

Tariff:
Energy Charge
Category of Consumers Fixed Charge
(Rs. per kWh)
Rs. 142/HP/month or Rs.
LV-6: Public Utilities 6.25
190/kW/month

Notes:
i. Fixed Charge is monthly minimum charge whether any energy is consumed
during the month or not.
ii. If the Recorded Demand exceeds the Sanctioned Load for any three
consecutive months, then the Sanctioned Load shall automatically be restated
to the highest demand recorded in these three months. In such cases of upward
restatement of Sanctioned Load, the load enhancement charges shall be
applicable; however, the Security Deposit shall not be required to be increased
correspondingly.
iii. If the Recorded Demand is lower than the Sanctioned Load for any three
consecutive months, then the Sanctioned Load can be restated to the highest
demand recorded in these three months at the option of the consumer.

11.1.7 LV-7: Information Technology & Export Oriented Textile Industries

Applicability
This tariff is applicable to Information Technology Industries and Export Oriented
Textile Industries having minimum Contract Demand of 50 kW.

Tariff:
Demand Charge on
Energy Charge
Category of Consumers billing demand
(Rs. per kWh)
(Rs./kW/Month)
LV-7: Information Technology &
150 5.15
Export Oriented Textile Industries

220 CSERC Tariff Order FY 2022-23


Note:
Demand Charge is payable as monthly minimum charge whether any energy is
consumed during the month or not.

11.1.8 LV 8: Temporary Supply

Applicability
This tariff is for connections that are temporary in nature. The tariff applicable shall
be as given for the respective category of consumer.

Provided that for construction purpose, a consumer shall be given a temporary


connection only.

Provided further that for a farmer requiring temporary agriculture pump connection
more than once within a period of one year from the date of disconnection of the
previous connection, no fresh paper formalities would be required.
Temporary supply cannot be demanded by a prospective consumer as a matter of right
but will normally be arranged by the Licensee when a requisition is made subject to
technical feasibility.

Tariff:
Fixed Charge and Energy Charge shall be billed at one and half times the normal
tariff as applicable to the corresponding consumer categories.

Provided that for Agricultural pump connections, the Fixed Charge and Energy
Charge shall be billed at the normal tariff applicable for LV-3 category.

Notes:
i. An amount equal to estimated bill for 3 months or for the period of temporary
connection requisitioned, whichever is less, is payable before serving the
temporary connection, subject to replenishment from time to time and
adjustment in the last bill after disconnection.
ii. No temporary connection shall be served without a meter.
iii. Connection and disconnection charge shall be paid as per the schedule of
miscellaneous charges.
iv. No rebates/concessions under any head shall be applicable to temporary
connections.
v. A month for the purpose of billing of temporary supply shall mean 30 days from
the date of connection or part thereof.

CSERC Tariff Order FY 2023-24 221


vi. In case connected load/maximum demand is found more than Sanctioned
load/contract demand, then the billing of excess load/supply shall be done for
the amount calculated as per para 1.1.11.

vii. Any expenditure made by the Licensee for providing temporary supply up to the
point of supply, shall be paid for by the consumer as per prescribed procedure.

viii. Temporary connections shall not be served unless suitable capacitors, wherever
applicable, are installed so as to ensure Power Factor of not less than 0.85
lagging.

ix. Surcharge at the rate of 2% per month or part thereof on the outstanding amount
of the bill shall be payable in addition, from the due date of payment of bill, if
the bill is not paid by the consumer within the period prescribed.

11.1.9 Terms and Conditions of L.V. Tariff


1. Energy will be supplied to the consumer ordinarily at a single point for the
entire premises of the consumer.

2. Sanctioned Load or Contract Demand/Maximum Demand infraction shall be


rounded off to the next whole number.

3. If the bills are not issued consecutively for three months or more for any LT
Consumer, billing on accumulated meter reading shall not be raised without
approval of concerned Executive Engineer of CSPDCL.

4. For the purpose of separate independent LV connection to HV Industrial


consumer in the same premises of HV industrial connection, to meet out its
essential load during emergency or non-availability of supply in HV connection
under LV 2 category, conditions as mentioned in Clause 4.40 of the
Chhattisgarh State Electricity Supply Code and its amendment, if any, shall be
applicable.

5. For the purpose of Demand Based Tariff (LV-2.2, LV-4 and LV-5)

i. Determination of Maximum Demand- The maximum demand means the


highest load measured by sliding window principle of measurement in
average kVA or average kW as the case may be at the point of supply of a
consumer during any consecutive period of 30 minutes during the billing
period.
ii. Billing Demand – The billing demand for the month shall be the actual
maximum kW demand of the consumer recorded during the month or 80%

222 CSERC Tariff Order FY 2022-23


of the Contract Demand, whichever is higher. The billing demand shall be
rounded off to the next whole number.

iii. Minimum Charge – The demand charge on contract demand (CD) is a


monthly minimum charge whether any energy is consumed during the
month or not.

6. The recorded demand for the respective month shall be reflected in the
consumer bill.

11.1.10 Power Factor Incentive and Surcharge


i. Consumers, falling under tariff categories LV-4: LV Agriculture Allied
Activities, LV 5- LV Industry, LV 6: Public Utilities and LV-7: Information
Technology and Export Oriented Textile Industries shall arrange to install
suitable low-tension capacitors of appropriate capacity at their cost. The
consumer also shall ensure that the capacitors installed by them properly
match with the actual requirement of the load so as to ensure average monthly
Power Factor of 0.9 or above. A consumer who fails to do so shall be liable to
pay Power Factor surcharge @ 35 paise per kWh on the entire consumption of
the month.

ii. All LV non-domestic consumers with Contracted Load of 15 kW or above


shall arrange to install suitable Low Tension capacitors of appropriate capacity
at their cost. The consumer shall ensure that the capacitors installed by him
properly match with the actual requirement of the load so as to ensure average
monthly Power Factor of 0.9 or above. A consumer who fails to do so will be
liable to pay Power Factor surcharge @ 35 paise per kWh on the entire
consumption of the month.

iii. All LV installations having welding transformer are required to install suitable
Low Tension capacitors so as to ensure Power Factor of not less than 0.9.
Consumers not complying with the above shall have to pay Power Factor
surcharge of 75 paise per kWh on the entire monthly consumption, provided
the load of the welding transformer(s) exceeds 25% of the total Sanctioned
load.

Note - For the purposes of computing the connected load of welding


transformers in kW, a Power Factor of 0.6 shall be applied to the kVA rating

CSERC Tariff Order FY 2023-24 223


of such welding transformers. The kVA rating can also be calculated on the
basis of load voltage and maximum load current on secondary side of welding
machine.

iv. The average monthly Power Factor recorded in the meter shall be considered
for billing of Power Factor surcharge or Power Factor incentive, as the case
maybe.

v. Levy of Power Factor surcharge as indicated above, shall be without prejudice


to the rights of CSPDCL to disconnect the consumer's installation after issue
of 15 days‟ notice if the average monthly Power Factor remains 0.7 or below
for a period of more than two consecutive months. It shall remain
disconnected till the consumer makes suitable arrangements to improve the
Power Factor.

vi. Notwithstanding the above, if the average monthly Power Factor of a new
consumer is found to be less than 0.9 at any time during the first six months
from the date of connection and if he maintains average monthly Power Factor
continuously in subsequent three months at not less than 0.9, then the
surcharge billed on account of low Power Factor during the said period shall
be withdrawn and credited in next month‟s bill.

vii. All categories of LV consumers in whose case power factor surcharge is


applicable; shall be eligible for Power Factor incentive for Power Factor of
above 0.95. Such incentive shall be payable @ 1% of the energy charges for
each 0.01 increase or part thereof in power factor above 0.95 up to unity
power factor. For example, consumers with Power Factor of 0.965 shall be
considered as 0.97 and be eligible for power factor incentive of 2% of energy
charges. Consumers with Power Factor of 0.964 shall be considered as 0.96
and be eligible for power factor incentive of 1% of energy charges.

11.1.11 Provisions of billing in case of Excess Supply

1. For Sanctioned load-based tariff


i. The consumers, except the domestic (LV-1) consumers, availing supply at
Sanctioned load-based tariff shall restrict their actual connected load within
the Sanctioned load. However, in case the actual connected load in any
224 CSERC Tariff Order FY 2022-23
month exceeds the Sanctioned load, the Sanctioned load-based tariff shall
apply only to the extent of Sanctioned load and corresponding units of
energy. The connected load in excess of Sanctioned load and corresponding
units of energy shall be treated as excess supply except the domestic
(LV-1) consumers. The excess supply so consumed in any month, shall be
charged at the rate of one and half times of the Sanctioned load based tariff
applicable to the consumer (fixed and energy charges and FPPAS charges)
for the excess connected load to the extent of 20% of Sanctioned load and
at the rate of two times of Sanctioned load based tariff if the excess
connected load is found beyond 20% of Sanctioned load for actual period
of enhancement of load or 6 months whichever is less, including the month
in which the existence of excess load is detected and shall be continued to
be billed till excess load is removed or Sanctioned load is enhanced.

ii. Where the recording facility of demand is available, the billing on account
of excess supply shall be restricted to the recorded month only.

iii. If the Recorded Demand exceeds the Sanctioned Load for any three
consecutive months, then the Sanctioned Load, as applicable, shall
automatically be restated to the highest demand recorded in these three
months;

iv. If the Recorded Demand is lower than the Sanctioned Load for any three
consecutive months, then the Sanctioned Load shall be restated to the
highest demand recorded in these three months at the option of the
consumer.

2. For Demand Based tariff consumers


i. Consumers availing supply at demand-based tariff (LV-2.2/LV-4.2/LV-5)
should at all times restrict their maximum demand to the contract demand
or Sanctioned load, whichever is applicable. However, contract demand
for the demand-based tariff consumer can be less than Sanctioned load. In
case the maximum demand in any month exceeds the contract demand, the
said demand-based tariff (LV–2.2/LV-4.2/LV-5) shall apply only to the
extent of the contract demand and corresponding units of energy. The
demand in excess of contract demand and corresponding units of energy

CSERC Tariff Order FY 2023-24 225


shall be treated as excess supply. The excess supply so availed in any
month, shall be charged at the rate of one and half times of the normal
tariff applicable to the consumer (fixed and energy charges and FPPAS
charges) for the excess demand to the extent of 20% of contract demand
and at the rate of two times of normal tariff if the excess demand is found
beyond 20% of contract demand.

ii. For the purpose of billing of excess supply, the billing demand and the
units of energy shall be determined as under:

a) Billing Demand: The demand in excess of the contract demand in any


month shall be the billing demand.
b) Units of Energy: the units of energy corresponding to kW portion of
the demand in excess of the contract demand shall be:-

EU= TU (1-CD/MD)

Where
EU – denotes excess units,
TU – denotes total units supplied during the month,
CD – denotes contract demand, and

MD – denotes actual maximum demand.

I. The excess supply availed in any month shall be charged along


with the monthly bill and shall be payable accordingly.

II. The above billing of excess supply at one and half times/two times
of the normal tariff shall be applicable to consumers without
prejudice to CSPDCL‟s right to discontinue supply in accordance
with the provisions contained in the Chhattisgarh State Electricity
Supply Code, 2011, as amended from time to time.

iii. If the Recorded Demand exceeds the Contracted Demand for any three
consecutive months, then the Contracted Demand, as applicable, shall
automatically be restated to the highest demand recorded in these three
months.

226 CSERC Tariff Order FY 2022-23


3. Delayed Payment Surcharge
If the bill is not paid by the consumer within the period (due date) prescribed for
payment of the bill, a surcharge @ 1.5% per month or part thereof, on the total
outstanding amount of the bill (including arrears, if any, but excluding amount
of surcharge), subject to minimum of Rs. 5 shall be payable in addition, from
the due date of payment as mentioned in the bill.

4. Additional Charges
Every Local Body shall pay an additional charge equivalent to any tax or fee
levied by it under the provisions of any law including the Corporation Act,
District Municipalities Act or Gram Panchayat Act on the poles, lines,
transformers and other installations through which the Local Body receives
supply.

5. Advance Payment Rebate


For advance payment made before commencement of consumption period for
which bill is to be prepared, a rebate @ 0.5% per month on the amount which
remains with the Licensee at the end of the calendar month excluding security
deposit, shall be credited to the account of consumer after adjusting any amount
payable to the Licensee subject to the net amount of advance being not less than
Rs.1000 and shall be adjustable in next month‟s bill.

6. Rounding off

The bill shall be rounded off to the nearest multiple of Rs.10. Difference, if any,
between the bill amount before and after rounding off, shall be adjusted in next
month‟s bill.

For example: - If the total amount of bill is Rs. 235.00, then the bill shall be
rounded off to Rs. 240 and Rs. 5.00 will be credited in next month‟s bill,
whereas if the total amount of bill is Rs. 234.95, then the bill will be rounded off
to Rs. 230 and Rs. 4.95 will be debited in next month‟s bill. In view of the
above provision, no surcharge will be levied on outstanding amount, which is
less than Rs. 10.

CSERC Tariff Order FY 2023-24 227


7. Applicability of tariff
In case of any dispute about applicability of tariff to a particular LV category,
the decision of the Commission shall be final and binding.

8. Tax or Duty
The tariff does not include any tax or duty, etc., on electrical energy that may be
payable at any time in accordance with any law in force. Such charges, if any,
shall be payable by the consumer in addition to tariff charges.

9. Meter Hire
Meter hire shall be charged as per the schedule of miscellaneous charges to all
categories of LV consumers except the consumers of domestic light and fan
category. Domestic light and fan category consumer shall not be required to pay
such charges.

10. Fuel and Power Purchase Adjustment Surcharge (FPPAS)


The Commission is likely to introduce the Fuel and Power Purchase Adjustment
Surcharge (FPPAS) formula consistent with the Electricity (Amendment) Rules,
2022, notified by Central Govt., which may be made effective from April 1,
2023.

FPPAS shall be levied on the energy charges on all the LV categories including
temporary supply. The FPPAS amount for CSPDCL shall be determined on
monthly basis.

Unless intimated otherwise by the Commission, FPPAS shall be computed and


charged by CSPDCL, in (n+2)th month, on the basis of actual variation, in cost
of fuel and power purchase and Inter-State Transmission Charges for the power
procured during the nth month. The percentage and the amount of the FPPAS
shall be shown separately in the consumers' bills. For example, the fuel and
power purchase adjustment surcharge on account of changes in tariff for power
supplied during the month of April of any financial year shall be computed and
billed in the month of June of the same financial year.

CSPDCL shall work out the amount of FPPAS and shall intimate the same and
manner of determination of the same to the Commission. The gist of

228 CSERC Tariff Order FY 2022-23


FPPAS computation shall be widely publicized by CSPDCL in the leading
newspapers of the State. Calculations of the FPPAS for the particular month
shall be displayed by CSPDCL on its website for the information of the
consumers.

11. Method of payment of Bills


(1) Consumer shall have the option to pay bills online or offline.

(2) Bill amount of more than five thousand rupees shall mandatorily be
paid online.

(3) For bill amount less than or equal to five thousand rupees, consumer
may pay the bill through cash or cheque or demand draft or electronic
clearing system at designated counters of a bank or through credit or
debit cards or online payment through distribution licensees‟ web portal
or any digital mode of payment and any change or further addition in the
mode of payment shall be more user friendly for the consumers than the
prevailing system.

Provided that the distribution licensee may stipulate a suitable incentive


or rebate for payment through online system for consumers who opt to
pay bill amount less than or equal to five thousand rupees.

(4) The distribution licensee shall establish online portal as well as sufficient
number of collection centres or drop boxes at suitable locations with
necessary facilities, where consumer can deposit the bill amount with
ease.

12. Conditions to have over-riding effect


All the above conditions of tariff shall be applicable to the consumer
notwithstanding the provisions, if any, in the agreement entered into by the
consumer with the Licensee.

11.2 Tariff Schedule for High Voltage (HV) Consumers

11.2.1 HV-1: Railway Traction


Applicability:
This tariff is applicable to the Railways for traction loads only.

CSERC Tariff Order FY 2023-24 229


Tariff:
Supply Voltage Demand Charge Energy Charge
(Rs./kVA/month) (Rs. per kVAh)
Railway Traction on
132 kV / 220 kV 375 4.55

Specific terms and conditions:


1. The maximum demand means the highest load measured by sliding window
principle of measurement in average kVA at the point of supply of a consumer
during any consecutive period of 15 minutes during the billing period.

2. Provided that if as a result of an emergency in the consumer‟s installation or in


the transmission lines supplying energy to the said traction sub-station, extra
load is availed by the consumer with prior intimation to the Licensee, the period
of such emergency shall not be taken into account for the purpose of working
out the maximum demand.

3. Provided further that as a result of emergency in the traction sub-station (TSS)


or in the transmission line supplying power, if the entire load of the TSS or part
thereof is transferred to adjacent TSS, the maximum demand (MD) of the TSS
for the month shall not be taken as less than the average MD recorded for the
previous three months during which no emergency had occurred.

4. In order to give impetus to electrification of railway network in the State, a


rebate of 10% in energy charges for new railway traction projects shall be
allowed for a period of five years from the date of connection for such new
projects for which Agreements for availing supply from the Licensee are
finalised during FY 2018-19.

5. Other terms and condition shall be as mentioned in the general terms and
conditions of HV tariff.

6. For traction sub-stations of Indian Railways, if Load Factor for any month is
above 20%, then a rebate of 20% shall be allowed on Energy Charge calculated
on entire energy consumption for that month.

230 CSERC Tariff Order FY 2022-23


11.2.2 HV-2: Mines

Applicability
This tariff is applicable to all types of mines, mines with stone crusher unit, stone
crusher, mixer, mixer with stone crushers, coal mines, coal washery, etc., for power,
lights, fans, cooling ventilation, etc., which shall mean and include all energy
consumption for mining purpose, and consumption for residential and general use
therein including offices, stores, canteen compound lighting, etc.

Tariff:
Supply Voltage Demand Charge Energy Charge
(Rs./kVA/month) (Rs. per kVAh)
220 kV supply 500 6.75
132 kV supply 500 6.90
33 kV supply 500 7.15
11 kV supply 500 7.45

11.2.3 HV-3: Other Industrial and General Purpose Non-Industrial

Applicability
1. This tariff is applicable to all types of industries including cement industries and
industries not covered under HV-1, HV-2 and HV-4 for power, lights, fans,
cooling ventilation, etc., which shall mean and include all energy consumption
in factory, and consumption for residential and general use therein including
offices, stores, canteen compound lighting, etc.

2. This tariff is also applicable for bulk supply at one point to establishment such
as Railways (other than traction), hospitals, offices, hotels, shopping malls,
electric charging centres for Vehicles, power supplied to outside of State (border
villages), educational institutions and other institutions, etc., having mixed load
or non-industrial and/or non-residential load. This tariff is also applicable to all
other HT consumers not covered specifically in any other HV tariff category.

3. This tariff is applicable to consumers availing supply at 220/132/33/11 kV for


manufacturing of plant, machinery and equipment used for generation of power
from renewable sources of energy including for the manufacturing of hydel
turbine, generator and related auxiliaries needed for small hydel plants up to 25
MW.

CSERC Tariff Order FY 2023-24 231


Tariff:
Demand Charge Energy Charge
Supply Voltage
(Rs./kVA/month) (Rs. per kVAh)

220 kV supply 375 6.45

132 kV supply 375 6.60

33 kV supply (Load factor >15%) 375 6.85

33 kV supply (Load factor <=15%) 190 7.05

11 kV supply (Load Factor >15%) 375 7.25

11 kV supply (Load Factor <=15%) 190 7.45

Notes:-
i. For charging stations of Electric Vehicles, a flat rate single part tariff of Rs. 5
per unit shall be applicable.
ii. A discount of 5% on Energy Charges shall be applicable for private clinics,
hospitals and nursing homes including X-ray plant, diagnostic centres and
pathological labs, situated in rural areas as defined by Government of
Chhattisgarh and all areas in Bastar avem Dakshin Kshetra Adivasi Vikas
Pradhikaran, and Sarguja avem Uttar Kshetra Adivasi Vikas Pradhikaran
Notified Vide Order dated August 22, 2005.
iii. A discount of 15% on Energy Charges shall be applicable for defence
establishments under Government of India.
iv. A discount of 5% on Energy Charges shall be applicable for rice mills/Poha and
Murmura mills

11.2.4 HV-4: Steel Industries

Applicability
This tariff is applicable to steel industries, mini-steel plant, rolling mills, sponge iron
plants, ferro alloy units, steel casting units, pipe rolling plant, iron ore pellet plant,
iron beneficiation plant and combination thereof including wire drawing units with or
without galvanizing unit, for power, lights, fans, cooling ventilation, etc., which shall
mean and include all energy consumption in factory, and consumption for residential
and general use therein including offices, stores, canteen compound lighting, etc.

232 CSERC Tariff Order FY 2022-23


Tariff:
Demand Charge Energy Charge
Supply Voltage
(Rs./kVA/month) (Rs. per kVAh)
220 kV supply 375.00 5.70
132 kV supply 375.00 5.85
33 kV supply (Load factor >15%)* 375.00 6.10
33 kV supply (Load factor <=15%)* 190.00 6.60
11 kV supply (Load Factor >15%)* 375.00 6.20
11 kV supply (Load Factor <=15%)* 190.00 7.00

Notes:-
*The applicable Load Factor limit for 33 kV and 11 kV supply for exclusive Rolling
mills consumers shall be 35%.

Further, to boost industrialization in the areas covered under "Bastar avem Dakshin
Kshetra Adivasi Vikas Pradhikaran" (notified vide Order dated August 22, 2005)
and "Sarguja avem Uttar Kshetra Adivasi Vikas Pradhikaran" (notified vide
Order dated August 22, 2005), a special rebate of 5% on energy charge is being
provided to the consumers starting production on or after April 1, 2017.

Load Factor Rebate


The consumers of this category shall be eligible for Load Factor rebate on Energy
Charges:

Monthly Load Rebate


Factor (LF)
50% - 50.99% rebate of 1% on normal Energy Charge calculated on entire
energy consumption
51% - 51.99% rebate of 2% on normal Energy Charge calculated on entire
energy consumption
52% - 52.99% rebate of 3% on normal Energy Charge calculated on entire
energy consumption
53% - 53.99% rebate of 4% on normal Energy Charge calculated on entire
energy consumption
54% - 54.99% rebate of 5% on normal Energy Charge calculated on entire
energy consumption
55% - 55.99% rebate of 6% on normal Energy Charge calculated on entire
energy consumption

CSERC Tariff Order FY 2023-24 233


Monthly Load Rebate
Factor (LF)
56% - 56.99% rebate of 7% on normal Energy Charge calculated on entire
energy consumption
57% - 57.99% rebate of 8% on normal Energy Charge calculated on entire
energy consumption
58% - 58.99% rebate of 9% on normal Energy Charge calculated on entire
energy consumption
59% - 59.99% rebate of 10% on normal Energy Charge calculated on entire
energy consumption
60% - 60.99% rebate of 11% on normal Energy Charge calculated on entire
energy consumption
61% - 61.99% rebate of 12% on normal Energy Charge calculated on entire
energy consumption
62% - 62.99% rebate of 13% on normal Energy Charge calculated on entire
energy consumption
rebate of 14% on normal Energy Charge calculated on entire
63% - 63.99%
energy consumption
rebate of 15% on normal Energy Charge calculated on entire
64% - 64.99%
energy consumption
rebate of 16% on normal Energy Charge calculated on entire
65% – 65.99%
energy consumption
rebate of 17% on normal Energy Charge calculated on entire
66% - 66.99%
energy consumption
rebate of 18% on normal Energy Charge calculated on entire
67% - 67.99%
energy consumption
rebate of 19% on normal Energy Charge calculated on entire
68% - 68.99%
energy consumption
rebate of 20% on normal Energy Charge calculated on entire
69% - 69.99%
energy consumption
rebate of 21% on normal Energy Charge calculated on entire
70% - 70.99%
energy consumption
rebate of 22% on normal Energy Charge calculated on entire
71% - 71.99%
energy consumption
rebate of 23% on normal Energy Charge calculated on entire
72% - 72.99%
energy consumption
rebate of 24% on normal Energy Charge calculated on entire
73% - 73.99%
energy consumption
rebate of 25% on normal Energy Charge calculated on entire
74% and above
energy consumption

Provided that in case the monthly Load Factor is 49.99% or below, then no Load
Factor Rebate shall be payable in that month:

234 CSERC Tariff Order FY 2022-23


Provided further that flat 30 hours per month of power-off (non-supply) shall be
considered for calculation of Load Factor only in case of industries connected at 33
kV and 11 kV:

Provided also that the Load Factor Rebate shall not be payable on the excess energy
consumed corresponding to exceeding contract demand for that billing month:

Provided also that the monthly Load Factor shall be rounded off to the lowest integer.

The licensee and consumers shall comply with all safety requirements specified under
the applicable laws and amendments thereof from time to time.

11.2.5 HV-5: Irrigation & Agriculture Allied Activities, Public Water Works
Applicability
1. This tariff shall be applicable for Chhattisgarh State Housing Board and
agriculture pump connections, irrigation pumps of lift irrigation schemes of
State Government or its agencies/co-operative societies, including colonies
developed and energy used for lighting pump houses.

2. This tariff is also applicable to the consumer availing supply at HV for the
purpose of pump/tube well connections, other equipment for tree plantation,
fisheries, hatcheries, mushroom cultivation, poultry farms, dairy, cattle breeding
farms, sericulture, tissue culture and aquaculture laboratories and milk chilling
plant and bakery for power, lights, fans, coolers, etc., which shall mean and
include all energy consumed in factory, offices, stores, canteen, compound
lighting, etc., and residential use therein.

3. This tariff shall be applicable for public utility water supply schemes, sewerage
treatment plants and sewage pumping installations run by P.H.E. Department,
Local Bodies, Gram Panchayat or any organization made responsible by the
Government to supply/maintain public water works/sewerage installation
including energy used for lighting pump house.

Tariff:

Supply Voltage Demand Charge Energy Charge


(Rs./kVA/month) (Rs. per kVAh)
Irrigation, Agriculture Allied Activities
375 5.85
& Public Water Works

CSERC Tariff Order FY 2023-24 235


11.2.6 HV-6: Residential

Applicability
This tariff shall be applicable for bulk supply at one point to colonies, multi-storied
residential buildings, townships, including townships of industries provided that
consumption of non-domestic nature for other general-purpose load (excluding
drinking water supply, sewage pumping and street light) shall not be more than 10%
of total monthly energy consumption.

In case the consumption of non-domestic nature for other general-purpose load


exceeds 10% of total monthly energy consumption, the tariff of HV-3: Other
Industrial and General Purpose Non-Industrial, shall be applicable on entire
consumption.

This tariff shall also be applicable to hospitals including educational institutions and
X-rays, etc., situated within its premises, run by charitable trusts / non-profit
organizations / societies registered under the Firms and Societies Act.

Tariff:
Demand Charge Energy Charge
Category of Consumers
(Rs./kVA/month) (Rs. per kVAh)
Residential 375 6.05

11.2.7 HV-7: Start-Up Power Tariff


Applicability
The tariff shall be applicable to those consumers who avail supply for start-up power
for their power plant (generating station and captive generating plant) at
400/220/132/33/11 kV.

Tariff:
Demand Charge Energy Charge
Supply Voltage
(Rs./kVA/month) (Rs. per kVAh)
400/220/132/33/11 Kv 200 8.35

Conditions for start-up power consumers:

i. Contract demand shall not exceed 10% of the highest capacity of generating unit
of the generating station/captive generating plant
236 CSERC Tariff Order FY 2022-23
ii. Captive generating plants, which do not have any co-located industrial load and
who use the grid for transmission and wheeling of electricity can avail start up-
power tariff.

iii. Captive generating plants, which have co-located industrial load are also entitled
for start-up power tariff.

iv. Drawal of power shall be restricted to within 10% of Load Factor based on the
Contract Demand in each month. In case the Load Factor in a month is recorded
beyond 10%, the demand charge shall be charged at double the normal rate.
Supply can also be disconnected if the monthly Load Factor exceeds 10% in any
two consecutive months. Load Factor shall be computed from contract demand.

v. Start-up power shall also be made available to the generator/captive generating


plant connected to CTU grid with proper accounting.

vi. This tariff shall also be applicable to generators for the consumption up to COD
of the plant.

vii. Generators who have not availed start-up connection but eventually draw power
from the grid shall be billed @ Rs 12 per kVAh. In case of captive generating
plant, which do not have any co-located industrial load and who use the grid for
transmission and wheeling of electricity, such CGP's, if they have not availed
start-up connection but eventually draw power, shall be billed @ Rs. 12 per
kVAh.

viii. In case of captive generating plant, which have co-located industrial load and
who have not availed start-up connection but eventually draws start-up power
from the grid shall be billed @ Rs. 12 per kVAh.
All renewable generators (biomass and small hydro) are exempted from
payment of demand charge for the first five years from the date of commercial
operation of their power plant, i.e., they will be required to pay only energy
charge during first five years from COD and full start-up tariff from sixth year
onwards. However, in case during first five years from the date of its
connection, if the actual demand exceeds the contract demand, the billing for
that month shall be as per other start-up power consumers exceeding contract
demand. In case if the Load Factor is within 10% but actual demand exceeds the
contract demand then also the billing for that month shall be as per other start-up
power consumer exceeding contract demand. In case, it is established that the
biomass based generator has used biomass in the lesser ratio than as mentioned

CSERC Tariff Order FY 2023-24 237


in the guidelines of the Ministry of New and Renewable Energy during any
financial year in first five years from the date of availing start up power tariff
then demand charge as per this tariff category (HV–7) shall also become payable
for the whole of such financial year and such payable amount will be billed in
three equal instalments after such happening comes to the notice of CSPDCL.

11.2.8 HV-8: Industries related to manufacturing of equipment for power generation


from renewable energy sources

Applicability
This tariff is applicable to consumers availing supply at 220/132/33/11 kV for
manufacturing of plant, machinery and equipment used for generation of power from
renewable sources of energy including for the manufacturing of hydel turbine,
generator and related auxiliaries needed for small hydel plants up to 25 MW but
excluding manufacturing of boilers, turbines, generators, and the related auxiliaries,
which otherwise can be used for generation of power from conventional source of
energy. This tariff shall also not be applicable for manufacturing of such common
machines/equipment/and other items such as electrical motors, structural items, nuts
bolts, etc. which can be used for other purposes also.

Tariff:
Demand charge Energy charge
Supply Voltage
(Rs./kVA/month) (Rs. per kVAh)

220/132/33/11 kV 130 4.15

11.2.9 HV-9: Information Technology & Export Oriented Textile Industries

Applicability

This tariff is applicable to Information Technology Industries and Export Oriented


Textile Industries having minimum contract demand of 50 kW.

Tariff:

Demand Charge Energy Charge


Category of Consumers
(Rs./kVA/month) (Rs. per kVAh)

HV-9: Information Technology


Industries and Export oriented Textile 150 4.25
Industries

238 CSERC Tariff Order FY 2022-23


Note:
Demand Charge is payable as monthly minimum charge, whether any energy is
consumed during the month or not.

11.2.10 HV-10: Temporary Connection at HV


Applicability
This tariff is applicable to all HV connections (other than the consumers availing Start
up power Tariff (HV-7)), of temporary nature at 220/132/33/11 kV.

Provided that for construction purpose, a consumer shall be given a temporary


connection only.

Temporary supply cannot be demanded by a prospective consumer as a matter of right


but will normally be arranged by the Licensee when a requisition is made subject to
technical feasibility.

Tariff:

One and half times of the normal Tariff applicable for the corresponding category of
consumer for demand and energy charge shall be applicable.

Notes:
i. An amount equal to estimated bill for 3 months or for the period requisitioned,
whichever is less, shall be payable in advance before the temporary connection is
served subject to replenishment from time to time and adjustment in the last bill
after disconnection.
ii. If maximum demand is found more than the contract demand in any billing
month, the billing shall be done at one and half times/two times of the energy
charges and Demand Charges as applicable, in case of exceeding contract
demand in permanent connection, and shall be calculated as per Clause 10 of
Terms & Conditions of HV tariff.
iii. Any expenditure made by CSPDCL up to the point of supply for giving
temporary connection shall be payable by the consumer as per prescribed
procedure.
iv. Connection and disconnection charges shall be paid separately.
v. No rebates/concessions under any head shall be applicable to temporary
connections.
vi. Month for the purpose of billing of temporary supply shall mean 30 days from
the date of connection or for part thereof.
CSERC Tariff Order FY 2023-24 239
vii. Other terms and conditions of the relevant category of tariff shall also be
applicable.
viii. Surcharge at 2% per month or part thereof on the outstanding amount of the bill
shall be payable in addition from the due date of payment of bill, if the bill is not
paid by the consumer within the period prescribed.

11.2.11 Time of Day Tariff


This tariff is applicable to HV-2, HV-3, and HV-4 tariff category. Under the Time of
Day (TOD) Tariff, electricity consumption in respect of HV industries for different
periods of the day, i.e., normal period, peak load period and off-peak load period,
shall be recorded by installing a TOD meter. Consumption recorded in different
periods shall be billed at the following rates on the tariff applicable to the consumer:

Period of Use Normal rate of Demand Charge Plus


(i) Normal period
Normal rate of Energy Charges
(5:00 a.m. to 6:00 p.m.)
(ii) Evening peak load period
120% of normal rate of Energy Charge
(6:00 p.m. to 11:00 p.m.)
(iii) Off-peak load period
80% of normal rate of Energy Charge
(11:00 p.m. to 5:00 a.m. of next day)

Applicability and Terms and Conditions of TOD tariff:


i. The terms and conditions of the applicable tariff (such as monthly tariff
minimum charge, etc.) shall continue to apply to a consumer to whom TOD
tariff is applicable.

ii. In case, the consumer exceeds the contract demand, the demand in excess and
the corresponding energy shall be billed at one and half/two times (as per
methodology specified in Para “Additional Charges for Exceeding Contract
Demand” of the Terms and Conditions of HV Tariff) of the normal tariff
applicable for the day time (i.e., 5.00 a.m. to 6.00 p.m.) irrespective of the time
of use.

11.2.12 Terms and Conditions of HV Tariff


The maximum and minimum contract demand for different supply voltages is
governed as per provisions of the Chhattisgarh State Electricity Supply Code, 2011

240 CSERC Tariff Order FY 2022-23


and its amendments thereof. Presently, the minimum and maximum permissible load
at respective supply voltage are as below except for independent distributed
renewable energy system plants (IDRES) which will be governed by CSERC (Grid
Interactive Distributed Renewable Energy Sources) Regulations, 2019:

Supply Voltage Minimum Maximum


11 kV 60 kVA 500 kVA
33 kV 60 kVA 15 MVA
132 kV 4 MVA 40 MVA
220 kV 15 MVA 150 MVA

Deviation in contract demand, if any, in respect of the above provisions on account of


technical reasons, may be permitted with the approval of the Commission and billing
shall be done accordingly. The HV consumers having contract demand exceeding the
maximum limit mentioned above for respective voltage of supply shall be billed as
specified at Clause 7 of Terms and Conditions of HV Tariff.

1. Point of Supply
Power will be supplied to consumers ordinarily at a single point for the entire
premises. In certain categories like coal mines, power may be supplied at more than
one point on the request of consumer subject to technical feasibility. HV industrial
consumers can avail separate LV supply as per Clause 4.40 of the Chhattisgarh State
Electricity Supply Code, 2011 and its amendments thereof, in the same premises.

2. Billing demand
The billing demand for any month shall be the maximum demand (in kVA) of the
consumer recorded during the billing month or 80% of the contract demand
whichever is higher. The billing demand shall be rounded off to the next whole
number.

3. Determination of Demand
The maximum demand means the highest load measured by sliding window principle
of measurement in average kVA at the point of supply of a consumer during any
consecutive period of 15 minutes during the billing period.

CSERC Tariff Order FY 2023-24 241


4. Minimum Charge
The demand charge on contract demand (CD) is a monthly minimum charge whether
any energy is consumed during the month or not.

5. Rounding off
The amount of HV energy bill shall be rounded off to the nearest multiple of Rs.10.

For example - the amount of Rs. 12345 will be rounded off to Rs. 12350 and Rs.
12344.95 shall be rounded off to Rs. 12340.

In view of the above provision no surcharge will be levied on outstanding amount,


which is less than Rs. 10.

6. Delayed Payment Surcharge


If the bill is not paid by the consumer within the period prescribed (due date) for
payment of the bill, a surcharge @ 1.5% per month or part thereof, on the total
outstanding amount of the bill (including arrears, if any but excluding amount of
surcharge), shall be payable in addition, from the due date of payment as mentioned in
the bill.

7. Additional charges for Local Bodies


Every Local Body shall pay an additional charge equivalent to any tax or fee levied
by it under the provisions of any law including the Corporation Act, District
Municipalities Act or Gram Panchayat Act on the poles, lines, transformers and other
installations through which the Local Body receives supply.

8. Advance Payment Rebate


For advance payment made before commencement of consumption period for which
bill is to be prepared, a rebate @ 0.5% per month on the amount, which remains with
the Licensee at the end of calendar month excluding security deposit, shall be credited
to the account of consumer after adjusting any amount payable to the Licensee,
subject to the net amount of advance being not less than Rs.20,000 and shall be
adjustable in next month‟s bill.

242 CSERC Tariff Order FY 2022-23


9. Additional Charge for Exceeding Contract Demand
The consumers should restrict their maximum demand to the extent of contract
demand. In case the maximum demand during any month exceeds the contract
demand, the tariff at normal rate shall apply only to the extent of the contract demand
and corresponding units of energy. The demand in excess of contract demand and
corresponding units of energy shall be treated as excess supply. The excess supply so
availed, if any, in any month shall be charged at one and half times of the normal
tariff applicable to the consumer (demand and energy charges) for the excess demand
to the extent of 20% of contract demand and at the rate of two times of normal tariff if
the excess demand is found beyond 20% of contract demand.

For all other consumer, where TOD is applicable:


i. During Off-Peak Hours, no additional charge will be levied on exceeding
Contract Demand up to a maximum limit of 20%.

ii. Beyond 120% of contract demand, excess supply will be billed as per prescribed
formula.

iii. Maximum recorded demand during off peak load period will not be considered
for the purpose of demand charges billing, i.e., demand charges will be levied
on maximum recorded demand during normal and peak load period.

Provided further that in case of excess supply to consumers (other than of HV-7 tariff
category) having minimum contract demand of 150 MVA, and having captive
generating plant(s) of capacity of at least 150 MW, such consumers shall have to pay
an additional demand charges of Rs. 20/kVA/month on the quantum of power availed
over and above its contract demand notwithstanding anything contained anywhere in
this order. Further, energy consumed corresponding to excess supply shall be billed at
normal tariff.

For the purpose of billing of excess supply, the billing demand and the units of energy
shall be determined as under:-

i. Billing Demand / Contract Demand:


The demand in excess of the contract demand in any month shall be the billing
demand/ contract demand of the excess supply.

CSERC Tariff Order FY 2023-24 243


ii. Units Energy:
The units of energy corresponding to kVA of the portion of the demand in excess of
the contract demand shall be:

EU= TU (1-CD/MD)

Where

EU - denotes units corresponding to excess supply,

TU - denotes total units supplied during the month,

CD - denotes contract demand, and

MD - denotes maximum demand.

The excess supply availed in any month shall be charged along with the monthly bill
and shall be payable by the consumer.

The billing of excess supply at one and half times/two times of the normal tariff
applicable to consumer is without prejudice to CSPDCL‟s right to discontinue the
supply in accordance with the provisions contained in the Chhattisgarh State
Electricity Supply Code, 2011 and its amendments thereof.

iii. No rebates/incentive is payable on such excess supply.

10. Additional Charge


The HV consumers having contract demand exceeding the maximum limit as
prescribed in Clause 1 of terms and conditions of HV tariff shall be levied additional
charges at the rate of 5% on Energy Charges of the respective consumer category.

11. Meter Hire


Meter hire shall be charged as per the schedule of miscellaneous charges to all
categories of HV consumers.

12. Tax or Duty


The tariff does not include any tax or duty, etc., on electrical energy that may be
payable at any time in accordance with any law/State Government Rules in force.
Such charges, if any, shall be payable by the consumer in addition to tariff charges.

244 CSERC Tariff Order FY 2022-23


13. Fuel and Power Purchase Adjustment Surcharge (FPPAS)
The Commission is likely to introduce the Fuel and Power Purchase Adjustment
Surcharge (FPPAS) formula consistent with the Electricity (Amendment) Rules,
2022, notified by Central Govt., which may be made effective from April 1, 2023.

FPPAS shall be levied on the energy charges on all the HV categories including
temporary supply. The FPPAS amount for CSPDCL shall be determined on monthly
basis.

Unless intimated otherwise by the Commission, FPPAS shall be computed and


charged by CSPDCL, in (n+2)th month, on the basis of actual variation, in cost of fuel
and power purchase and Inter-state Transmission Charges for the power procured
during the nth month. The percentage and the amount of the FPPAS shall be shown
separately in the consumers' bills. For example, the fuel and power purchase
adjustment surcharge on account of changes in tariff for power supplied during the
month of April of any financial year shall be computed and billed in the month of
June of the same financial year.

CSPDCL shall work out the amount of FPPAS and shall intimate the same and
manner of determination of the same to the Commission. The gist of FPPAS
computation shall be widely publicized by CSPDCL in the leading newspapers of the
State. Calculations of the FPPAS for the particular month shall be displayed by
CSPDCL on its website for the information of the consumers.

14. Dispute on applicability of tariff


In case of any dispute on applicability of tariff on a particular category of HV
industry/ consumer, the decision of the Commission shall be final and binding.

All the above conditions of tariff shall be applicable to the consumer notwithstanding
the provisions, if any, in the agreement entered into by the consumer with the
Licensee.

15. Parallel Operation Charges (POC)


Parallel Operation Charges shall be payable by CPP to CSPDCL for its captive and
non-captive load at the rate of 13 paise/kWh.

CSERC Tariff Order FY 2023-24 245


16. Method of payment of Bills
(1) Consumer shall have the option to pay bills online or offline.

(2) Bill amount of more than five thousand rupees shall mandatorily be paid
online.

(3) For bill amounts less than or equal to five thousand rupees consumer may
pay the bill through cash or cheque or demand draft or electronic clearing
system at designated counters of a bank or through credit or debit cards or
online payment through distribution licensees‟ web portal or any digital mode
of payment and any change or further addition in the mode of payment shall
be more user friendly for the consumers than the prevailing system.

Provided that the distribution licensee may stipulate a suitable incentive or


rebate for payment through online system for consumers who opt to pay bill
amount less than or equal to five thousand rupees.

(4) The distribution licensee shall establish online portal as well as sufficient
number of collection centres or drop boxes at suitable locations with necessary
facilities, where consumer can deposit the bill amount with ease.

11.3 Open Access Charges


1. Transmission Charges
The long-term and medium-term open access customers including CSPDCL shall be
required to pay the Annual Transmission Charges approved by the Commission. Bills
shall be raised for Transmission Charge on monthly basis by the STU (CSPTCL), and
payments shall be made by the beneficiaries and long-term and medium-term open
access customers directly to the CSPTCL. These monthly charges shall be shared by
the long-term open access customers and medium-term open access customers as per
allotted capacity proportionately. The monthly transmission charge is Rs. 100.57
Crore.

For short-term open access customer: Rs. 363.40 per MWh (or Rs. 0.3634 per kWh)
for the energy computed as per the provisions made in Regulation 33 of the CSERC
(Connectivity and Intra State Open access) Regulations, 2011 and its subsequent
amendment(s)/revision, if any, at 100% Load Factor for transmission. The same
charges shall be applicable for both collective and bilateral transactions at the point or
points of injection.

246 CSERC Tariff Order FY 2022-23


2. Energy Losses for Transmission
Transmission Losses of 3% for the energy scheduled for transmission at the point or
points of injection shall be recoverable from open access customers.

3. Wheeling Charges
For long-term, medium-term and short-term open access customer: Rs. 282.70 per
MWh (or Rs. 0.2827 per kWh) for the energy computed as per the provisions made in
Regulation 33 of the CSERC (Connectivity and Intra State Open access) Regulations,
2011 and its subsequent amendment(s)/revision, if any, at 100% load factor for
wheeling. The same charges shall be applicable for both collective and bilateral
transactions at the point of injection.

4. Energy losses for distribution


Distribution Losses of 6% for the energy scheduled for distribution at the point or
points of injection at 33 kV side of 33/11 kV sub-station shall be recoverable from
open access customers.

5. Operating Charges
The short-term open access customer shall pay the Operating Charges to SLDC at the
rate of Rs. 2000 per day.

6. Reactive Charges
Reactive Energy Charges shall be levied at the rate of 27 paise per kVARh.

7. Cross Subsidy Charges


i. For 220 kV and 132 kV consumers Rs. 1.28 per kWh (which is 90% of
the computed value of Rs. 1.43 per kWh).

ii. For 33 kV consumers Rs. 2.35 per kWh (which is 90% of the
computed value of Rs. 2.61 per kWh).

8. Standby Charges
The Standby Charges for consumers availing open access (using transmission and/or
distribution system of Licensee) and who draw power from the grid up to the
contracted capacity of open access during the outage of generating plant/CPP shall be
1.5 times of the per kWh weighted average tariff of HV consumers, which is Rs.
10.26 per kWh (1.5 times of the average billing rate of Rs.6.84 per kWh). For drawal
of power in excess of the contracted capacity of open access, the tariff for availing

CSERC Tariff Order FY 2023-24 247


standby support from the grid shall be two times of the per unit weighted average
tariff of HV consumers, which is Rs.13.68 per kWh (2 times of the average billing
rate of Rs. 6.84 per kWh). Further, in case of outage of CPP supplying power to
captive/non-captive consumer who has reduced its contract demand to zero and also
availed open access draws power of CSPDCL, then billing of such power drawn shall
be done as per the standby charges mentioned above.

9. Intra-State Open Access Charges for Renewable Energy transactions


a) Transmission Charges in cash for long-term/medium-term/short-term
open access - NIL

b) Wheeling Charges in cash for long-term/medium-term/short-term open


access - NIL

c) SLDC Charges (Operating Charges) for long-term/medium-term/short-


term open access - NIL

d) The Open Access customers availing long-term/medium-term/short-term


open access customers shall bear the energy loss specified as under:

a. Energy Losses for using only the Transmission system of CSPTCL


shall be 3%.

b. Energy Losses/for using only distribution system of CSPDCL shall


be 6%.

c. Energy losses for using both the transmission system of CSPTCL


and distribution system of CSPDCL or Combination thereof shall be
6%.

e) Cross-Subsidy Surcharge

i. A consumer availing open access is required to pay the cross-


subsidy surcharge.

ii. In case a generating company is an open access customer and is


supplying power to a consumer of the State, the liability of paying
cross-subsidy surcharge shall be on the consumer. If a captive
generating plant avails open access for supplying power to its
captive users, and if the captive users do not fulfil the requirement

248 CSERC Tariff Order FY 2022-23


of captive users in a financial year as prescribed in the Electricity
Rules, 2005, then that end user/s shall be liable to pay the Cross-
Subsidy Surcharge.

iii. The Cross-Subsidy Surcharge payable is 50% of the Cross


Subsidy Surcharge determined for that year, which is as under:

a) For 220 kV and 132 kV consumers Rs.0.64 per kWh.

b) For 33 kV consumers Rs. 1.17 per kWh.

In case of a consumer receiving power from Solar power plants


through open access, Cross Subsidy Surcharge shall be applicable
as per the provisions of CSERC (Grid Interactive Distributed
Renewable Energy Sources) Regulations, 2019, as amended from
time to time and Orders thereunder.

iv. In case of a consumer receiving power from biomass based power


generating plants through open access, if it is established that the
biomass based power generating plants supplying power to such
consumer has used biomass in the lesser ratio than as mentioned in
the guidelines of the Ministry of New and Renewable Energy
during any financial year, then the relaxations at (iii) above given
to the open access consumer shall be treated as withdrawn for that
financial year and the biomass generator shall be liable to pay to
CSPDCL full Cross Subsidy Surcharge.

CSERC Tariff Order FY 2023-24 249


12 DIRECTIVES
12.1 Directive to CSPDCL
The Commission has given specific directives to CSPDCL in this Order, in order to
facilitate improvement in operational efficiency. CSPDCL should comply with all
these directives and submit quarterly reports to the Commission regarding status of
compliance of these directives. CSPDCL should also include a Chapter on
Compliance of Directives along with its future ARR and Tariff Petitions.

12.1.1 Distribution Losses


Observations
To reduce energy loss in the distribution system, Division-wise Distribution Loss
target is required to be fixed along with the regular monitoring of the achievement of
the same.

Directives
In view of the above observation, following directives are given:
1. CSPDCL is directed to submit Division-wise loss reduction trajectory for FY
2023-24 by 30 June 2023 and submit quarterly report for the same.
2. CSPDCL should submit the achievement in respect of Division-wise actual loss
reduction vis-à-vis loss reduction trajectory for FY 2022-23 along with truing up
petition for FY 2022-23.

12.1.2 Distribution Transformer (DT) Metering


Observations
In tariff order for FY 2022-23, the Commission has directed CSPDCL to submit an
action plan to achieve 100% DT metering target. In response, CSPDCL has submitted
that it will achieve this target by FY 2023-24.

Directives
In view of the above, CSPDCL is directed to submit quarterly progress report of DT
metering.

12.1.3 Separation of Agriculture Feeders


Observations
In compliance to the directive given to CSPDCL regarding separation of agriculture
feeders, CSPDCL has submitted that 1067 nos. feeders have been proposed under
agriculture feeder separation in RDSS which will be completed by the year 2026.

Directives
In regard to above, CSPDCL is directed to submit quarterly progress report for
separation of agriculture feeders.

250 CSERC Tariff Order FY 2022-23


12.1.4 Agriculture Metering
Observations

In the Tariff Order 2022-23, the Commission had directed CSPDCL to ensure proper
metering of agricultural connections and timely reading of meters. In compliance,
CSPDCL submitted that 66.52% agriculture connections are billed on actual metered
units. Balance connections are billed on assessment basis, based on the consumption
of dedicated agriculture feeder/dedicated agriculture DTs.

Directives
In view of the above, CSPDCL is directed to submit an action plan for ensuring 100%
metering of agricultural connections 30 June 2023 and submit quarterly report for the
same.

12.1.5 Burnt/Defective Meters


Observation
Despite of several directives, CSPDCL could not bring down the burnt/defective
meter cases within the prescribed ceiling limit.

Directives
In view of the above, CSPDCL is directed to submit an action plan to curb the large
number of burnt/defective energy meters by 30th June 2023 and submit the quarterly
status report for the same.

12.1.6 Reduction in Aggregate Technical and Commercial (AT&C) Loss


Observations
AT&C loss is a critical factor which depicts the financial health of a distribution
licensee.

Directives
In view of the above, CSPDCL should identify one division in each circle where the
AT&C Losses are the highest and submit a detailed Action Plan for reduction of the
same.

CSERC Tariff Order FY 2023-24 251


Annexure-I - List of persons who submitted written submissions

1. Shri S. G. Oak, General Secretary, CS Retired Power Engineers-Officers Association,


Doongaji Colony, Raipur (CG)
2. Shri Sanjeev Jain, Sr. Manager (Legal & Regulatory), Bharti Airtel Limited, Vijay
Nagar, Indore (MP)
3. Shri S.K.Goyal, Director, Shri Bajrang Power & Ispat Ltd., Raipur (CG)
4. Shri Tilak Raj Dua, Director General, Digital Infrastructure Providers Association, Gole
Market, New Delhi
5. Lt. Gen. Dr. S. P. Kochhar, Director General, COAI (Cellular Operators Association of
India) New Delhi
6. Shri Hari Ram, Chief Electrical Engineer (EEM), South East Central Railway, Bilaspur
(CG)
7. Shri Bhupesh Kumar Verma, Prantiya Adhyaksha CG Vidyut Mandal Ptropadhi
Abhyanta Sangh, Raipur (CG)
8. Shri Vikram Jain, Director, SBT Textiles Pvt. Ltd., Raipur (CG)
9. Shri Shiv Shankar Dani, President, Chhattisgarh Printers Association, Telibandha,
Raipur (CG)
10. Shri Surya Prakash Rathi, Maheshwari and Company, Bilaspur Road, Birgaon, Raipur
(CG)
11. Shri Vikas Agrawal President Chhattisgarh Mini Steel Plant Association, Raipur (CG)
12. Er. Shri Shyam Kabra, Confederation of Electricity Consumers of Chhattisgarh
13. Ms. Jyoti Agrwal, Bajaj Furniture, Raipur (CG)
14. Shri Surendra Shukla, Prantiya Adhyaksha, Chhattisgarh Vidyut Karmchari Sangh
(Federation) Raipur
15. M/s Amril Metals and Gases LLP, Urla, Raipur (CG)
16. Smt. Sunila Jain Advocate, Malviya Road, Raipur (CG)
17. Shri Paresh Kalla, Vice President (Power Plant) M/s Jayaswal Neco Industries Ltd.
18. Shri Jai Nanvani, Vice President, Chhattisgarh Chamber of Commerce & Industries,
Raipur (CG)
19. Shri Abhishek Garg
20. Shri Aman Kumar Singh, Reliance JIO Infocom Limited, Raipur (CG)
21. Telangana State Power Coordination Committee, Hyderabad

252 CSERC Tariff Order FY 2022-23


Annexure-II - List of persons who submitted comments during hearing

1. Er. Shri Shyam Kabra, Confederation of Electricity Consumers of Chhattisgarh

2. Shri Loknath Nayak, Saraypali (CG)

3. Shri R. K. Gupta, Durg

4. Shri Surendra Jain, Reliance Jio Infocom Limited

5. Shri Aman Kumar Singh, Reliance Jio Infocom Limited

6. Shri Abhishek Garg, Raipur

7. Shri Yogesh Partati, South East Central Railway, Bilaspur

8. Shri Paresh Kalla, Vice President (Power Plant) M/s Jayaswal Neco Industries Ltd.

9. Shri P. N. Singh, CG Retired Power Engineers-Officers Association

CSERC Tariff Order FY 2023-24 253


Annexure-III - List of Members who attend the State Advisory Committee (SAC)
meeting

1. Shri Manoj Khare, Managing Director, CSPDCL

2. Shri Amit Verma, Electrical Engg., Grahak Panchayat, Raipur

3. Shri Umesh Chitlangia, President, Confederation of Indian Industries, Raipur

4. Shri Jay Nanvani, Vice President, Chhattisgarh Chamber of Commerce and


Industries, Raipur

5. Shri Vikram Jain, General Secretary, Urla Industries Association, Raipur

6. Shri Sanjeev Jain, CREDA, Raipur

7. Smt. Dr. Shubhrata Gupta, Professor, Electrical Department, NIT, Raipur

254 CSERC Tariff Order FY 2022-23


Annexure-IV
FORMAT-I
Details/Information for Computation of Fuel & other expenses variation
Name of the Company : Chhattisgarh State Power Generation Company Limited
Name of the Power Station : Hasdeo Thermal Power Station - HTPS
Description Unit Considered For the
in Tariff Month of-----
order
a Quantity of Coal supplied by Coal (MMT)
Company
b Adjustment (+/-) in quantity supplied (MMT)
by Coal Company
c Coal supplied by Coal Company (a+b) (MMT)
d Normative Transit & Handling Losses % 0.20% 0.20%
e Normative Transit & Handling Losses (MMT)
(cXd) -
f Net coal / Lignite Supplied (c-e) (MMT) -
g Amount charged by the Coal Company (Rs.)
h Adjustment (+/-) in amount charged by (Rs.)
Coal Company
i Net amount charged for Coal (g+h) (Rs.)
j Rate of Coal for the period =(i/(f*10^6)) Rs/MT 1,810.44
k Coal Sampling Fes (Rs.)
l Transportation Charge Rs/MT 82.05 82.05
m Landed Price of Coal per MT Rs./MT 1,897.68
(j+l+(k/(f*10^6)))
n Average GCV of coal as received (kCal/Kg) 3,656.40
o Normative SHR Kcal/ 2,650.00 2,650.00
KWh
p Normative Specific Oil Consumption ml/ KWh 0.80 0.80
q GCV of Secondary Fuel (Oil) Kcal/ml 10.00 10.00
r Normative Auxiliary Consumption % 9.70% 9.70
s ECR of Coal for the Period= Rs/ KWh
((o-(pxq))/(n)*(m/1000)/(1-r)
t ECR of Coal as considered in Tariff order Rs/ KWh 1.519
u Change in ECR of Coal (s-t) Rs/ KWh
v Scheduled Generation during the Period KWh
w Fuel & other expenses variation for the Rs
Period (uXv)
Note-
1. Values to be filled in shaded cells only. Adjustment towards all other parameters
shall be taken care of at the time of True Up.
2. Other cells carry either computed values or fixed values.
3. For computed values formula have been indicated in the particulars column.
4. ECR to be worked out to third digit

CSERC Tariff Order FY 2023-24 255


FORMAT-I
Details/Information for Computation of Fuel & other expenses variation
Name of the Company : Chhattisgarh State Power Generation Company Limited
Name of the Power Station : 1X500 MW Korba West Thermal Power Plant (KWTPP)

Description Unit Considered For the


in Tariff Month of---
order --
a Quantity of Coal supplied by Coal (MMT)
Company
b Adjustment (+/-) in quantity supplied (MMT)
by Coal Company
c Coal supplied by Coal Company (a+b) (MMT)
d Normative Transit & Handling Losses % 0.20% 0.20%
e Normative Transit & Handling Losses (MMT) -
(cXd)
f Net coal / Lignite Supplied (c-e) (MMT) -
g Amount charged by the Coal Company (Rs.)
h Adjustment (+/-) in amount charged by (Rs.)
Coal Company
i Net amount charged for Coal (g+h) (Rs.)
j Rate of Coal for the period =(i/(f*10^6)) Rs/MT 1,810.44
k Coal Sampling Fes (Rs.)
l Transportation Charge Rs/MT 82.05 82.05
m Landed Price of Coal per MT Rs./MT 1,897.68
(j+l+(k/(f*10^6)))
n Average GCV of coal as received (kCal/Kg) 3,656.40 3,656.40
o Normative SHR Kcal/KWh 2,390.00 2,390.00
p Normative Specific Oil Consumption ml/ KWh 0.50 0.50
q GCV of Secondary Fuel (Oil) Kcal/ml 10.00 10.00
r Normative Auxiliary Consumption % 5.25% 5.25
s ECR of Coal for the Period= Rs/ KWh
((o-(pxq))/(n)*(m/1000)/(1-r)
t ECR of Coal as considered in Tariff order Rs/ KWh 1.306
u Change in ECR of Coal (s-t) Rs/ KWh
v Scheduled Generation during the Period KWh
w Fuel & other expenses variation for the Rs
Period (uXv)
Note-
1. Values to be filled in shaded cells only. Adjustment towards all other parameters
shall be taken care of at the time of True Up.
2. Other cells carry either computed values or fixed values.
3. For computed values formula have been indicated in the particulars column.
4. ECR to be worked out to third digit.

256 CSERC Tariff Order FY 2022-23


FORMAT-I
Details/Information for Computation of Fuel & other expenses variation
Name of the Company: Chhattisgarh State Power Generation Company Limited
Name of the Power Station: Dr. Shyama Prasad Mukharjee Thermal Power Station - DSPM
TPS
Description Unit Considered For the
in Tariff Month of----
order
a Quantity of Coal supplied by Coal Company (MMT)
b Adjustment (+/-) in quantity supplied by (MMT)
Coal Company
c Coal supplied by Coal Company (a+b) (MMT)
d Normative Transit & Handling Losses % 0.20% 0.20%
e Normative Transit & Handling Losses (cXd) (MMT) -
f Net coal Supplied (c-e) (MMT) -
g Amount charged by the Coal Company (Rs.)
h Adjustment (+/-) in amount charged by (Rs.)
Coal Company
i Net amount Charged for Coal (g+h) (Rs.)
j Rate of Coal for the period =(i/(fX10^6)) Rs/MT 1,827.86
k Transportation Cost Paid to railways Rs
l Transportation Charge rate paid to Railways Rs/MT 192.59
(k/(fX10^6))
m Other Charges (per Ton) towards transportation Rs/MT 6.25 6.25
n Coal Sampling Fees Rs
o Total per ton Transportation Charges including Rs./MT 204.03
coal sampling fees (l+m+(n/(f*10^6)))
p Landed Price of Coal per MT (j+o) Rs./MT 2,031.89
q Average GCV of coal as received (kCal/Kg 3,269.32
)
r Normative SHR Kcal/ 2,430 2,430
KWh
s Normative Specific Oil Consumption ml/ KWh 0.50 0.50
t GCV of Secondary Fuel (Oil) Kcal/ml 10.00 10.00
u Normative Auxiliary Consumption % 9.00% 9.00
v ECR of coal for the Period= Rs/ KWh
((r-(sxt))/(q)*(p/1000)/(1-u)
w ECR of Coal as considered in Tariff order Rs/ KWh 1.656
x Change in ECR Coal (v-w) Rs/ KWh
y Scheduled Generation during the Period Kwh
z Fuel & other expenses variation for the Period Rs
(x X y)
Note-
1. Values to be filled in shaded cells only. Adjustment towards all other parameters
shall be taken care of at the time of True Up.
2. Other cells carry either computed values or fixed values.
3. For computed values formula have been indicated in the particulars column.
4. ECR to be worked out to third digit

CSERC Tariff Order FY 2023-24 257


FORMAT-I
Details/Information for Computation of Fuel & other expenses variation
Name of the Company : Chhattisgarh State Power Generation Company Limited
Name of the Power Station : Marwa Thermal Power Plant - ABVTPS ( consolidated =>
Gharghoda + Robertson )
Description Unit Considered in For the
Tariff order Month of-----
a Quantity of Coal Transported by railway (MMT) -
from Robertson siding
b Quantity of Coal Transported by railway (MMT) -
from Gharghoda siding
c Total Coal transferred through rail ( a+b) (MMT)
d Per ton Transportation charges from Rs/MT
Robertson siding
e Per ton Transportation charges from Rs/MT
Gharghoda siding
f Adjustment in transportation charges for Rs
the month of…………..
g Weigted average transportation rate of Rs/MT
Coal {(aXd+bXe)/c}+(f/(c*10^6))
h Input Price of Coal at Mine End as per Rs/MT For FY 2023-
T.O. 24-Rs1511.05,
FY 2024-25-
Rs1488.99
i Coal Sampling Fees Rs
j Other charges of Coal Transport Rs/MT 6.31 6.31
k Normative Transit Loss % 0.80% 0.80%
l Total landed Cost of Coal Rs/MT For FY 2023-
{((g+h+j+(i/(c*10^6))))/((1-k)} 24-Rs 2603.02,
FY 2024-25-Rs
2580.78
m GCV of coal as received (kCal/Kg) 3,628.91
n Normative SHR Kcal/Kwh 2,390.00 2,390.00
o Normative Specific Oil Consumption ml/ KWh 0.50 0.50
p GCV of Secondary Fuel (Oil) Kcal/ml 10.00 10.00
q Normative Auxiliary Consumption % 5.25% 5.25%
r Coal ECR for the Period= ((n- Rs/ KWh
(oxp))/(m)*(l/1000)/(1-q)
s Coal ECR as considered in Tariff order Rs/ KWh For FY 2023-
24-Rs 1.806, FY
2024-25-Rs
1.790
t Change in ECR Coal (r-s) Rs/ KWh
u Scheduled Generation during the Period Kwh
v Fuel & other expenses variation for the Rs
Period (tXu)

258 CSERC Tariff Order FY 2022-23


FORMAT-I (a)
Name of the Power Station : Marwa Thermal Power Plant – ABVTPS (Robertson )

For the
Description Unit
Month of-----
a Quantity of Coal transferred by railway (RR quantity) MMT
b Transportation Cost Paid to railways Rs
c Transportation rate paid to Railways = b/a/10^6 Rs/MT
d Road Transportation rate ( inclusive of price variaton
Rs/MT
and GST@18%)
e Total Transportation rate (c+d) Rs/MT

FORMAT-I (b)
Name of the Power Station : Marwa Thermal Power Plant - ABVTPS ( Gharghoda )
For the
Description Unit
Month of-----
a Quantity of Coal transferred by railway (RR quantity) MMT
b Transportation Cost Paid to railways Rs
c Transportation rate paid to Railways = b/a/10^6 Rs/MT
d Road Transportation rate ( inclusive of price variaton
Rs/MT
and GST@18%)
e Total Transportation rate (c+d) Rs/MT

Note-
1. Values to be filled in shaded cells only. Adjustment towards all other parameters shall
be taken care of at the time of True Up.
2. Other cells carry either computed values or fixed values.
3. For computed values formula have been indicated in the particulars column.
4. ECR to be worked out to third digit

CSERC Tariff Order FY 2023-24 259


Annexure-V – Revenue from Sale of Electricity at Approved Tariffs for CSPDCL for FY 2023-24

260 CSERC Tariff Order FY 2022-23


CSERC Tariff Order FY 2023-24 261
262 CSERC Tariff Order FY 2022-23

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