MSEDCL Energy Rates 2024-25
MSEDCL Energy Rates 2024-25
FY 2023-24
Category Units Fixed/Demand Energy Wheeling
Charge Charge Charge
HT IX: HT – Electric Vehicle Charging
Rs/kVA/mth 70.00 4.96 0.54
Station
Table 8-25: Summary of HT Tariff for FY 2024-25, effective from 1 April, 2024
FY 2024-25
Category Units Fixed/Demand Energy Wheeling
Charge Charge Charge
EHV
HT I (A) HT - Industry Rs/kVA/mth 472.00 6.73 -
HT I (B): HT - Industry (Seasonal) Rs/kVA/mth 472.00 6.99 -
HT II: HT – Commercial Rs/kVA/mth 472.00 9.30 -
HT III : HT - Railways/Metro/Monorail
Rs/kVA/mth 472.00 5.31 -
Traction
HT IV: HT - Public Water Works Rs/kVA/mth 472.00 6.17 -
HT V(A): HT - Agriculture Pumpsets Rs/kVA/mth 84.00 3.69 -
HT V(B): HT - Agriculture - Others Rs/kVA/mth 84.00 5.10 -
HT VI: HT - Group Housing Societies
Rs/kVA/mth 376.00 5.20 -
(Residential)
HT VIII(A): HT - Public Services-Gov. Rs/kVA/mth 472.00 7.24 -
HT VIII(B): HT - Public Services-Others Rs/kVA/mth 472.00 7.31 -
HT IX: HT – Electric Vehicle Charging
Rs/kVA/mth 70.00 4.97 -
Station
HT
HT I (A) HT - Industry Sub-total Rs/kVA/mth 472.00 6.73 0.53
HT I (B): HT - Industry (Seasonal) Rs/kVA/mth 472.00 6.99 0.53
HT II: HT – Commercial Rs/kVA/mth 472.00 9.30 0.53
HT III : HT - Railways/Metro/Monorail
Rs/kVA/mth 472.00 5.31 0.53
Traction
HT IV: HT - Public Water Works Rs/kVA/mth 472.00 6.17 0.53
HT V(A): HT - Agriculture Pumpsets Rs/kVA/mth 84.00 3.69 0.53
HT V(B): HT - Agriculture - Others Rs/kVA/mth 84.00 5.10 0.53
HT VI: HT - Group Housing Societies
Rs/kVA/mth 376.00 5.20 0.53
(Residential)
HT VIII(A): HT - Public Services-Gov. Rs/kVA/mth 472.00 7.24 0.53
HT VIII(B): HT - Public Services-Others Rs/kVA/mth 472.00 7.31 0.53
HT IX: HT – Electric Vehicle Charging
Rs/kVA/mth 70.00 4.97 0.53
Station
MSEDCL’s Submission
8.13.1 It has been observed that certain consumers are taking the benefit of lacunae in system of
bloc window method of Maximum Demand recording and thereby getting the benefit of
lower MD recording.
8.13.2 Petitioner submitted that, as per the Regulation 2.1 (p) of the MERC (Electricity Supply
Code and Other Conditions of Supply) Regulations 2005, the Maximum Demand (MD) is
defined as twice the largest number of kWh or kVAh supplied and taken during any
consecutive thirty minute blocks in that period, which is the same definition as provided by
the Commission in MTR Order dated 12th September 2018 (case No.195 of 2017).
8.13.3 Petitioner submitted that “IS 14697” is INDIAN STANDARD for AC static CT/PT
operated Energy meters and specifies about the demand integration period i.e. 15 or 30
minutes.
8.13.4 Petitioner submitted that CBIP’s “guide on Static energy meters-Specification and testing”
has mentioned two methods i.e. block and sliding window method for determination of the
MD. In sliding window method determination of the MD is based on 30 min DIP (Demand
Integration Period). In block window method, the MD is determined over a fixed time slot
of 30 min i.e. from 10:00 to 10:30 hrs. 10:30 to 11:00 hrs…. so on. The new Demand
Integration Period (DIP) starts only after the end of previous DIP.
8.13.5 In block window method, the MD is integrated over a fixed block of time as per the meter
clock i.e. from 10:00 to 10:30 hrs or 10:30 to 11:00 hrs. In this method, there is one
disadvantage i.e. consumer with higher demand can split his load in two consecutive time
slots such that the demand is split in two blocks and MD recorded is less than the actual
load on the system. This split high load than sanctioned contract demand is harmful to the
grid and pose difficulties to Distribution Company for meeting demand. Hence, sliding
window method is incorporated in new meters to determine demand more accurately, which
complies with MERC Regulations, Tariff Order, IS and CBIP standards.
8.13.6 In the revised methodology determination of Maximum Demand, the Demand Integration
Period (DIP) of consecutive 30 min as specified in the MERC (Electricity Supply Code and
other Conditions of Supply) Regulation 2005 is maintained and considered for measuring,
recording & billing the maximum demand of consumer and is in line the IS and CBIP Guide.
8.13.7 Petitioner stated that FAQs regarding kVA Maximum Demand calculation are available on
MSEDCL’s websites.
8.13.8 Petitioner submitted that it has installed new technology meters with a sliding window for
recording maximum demand in consecutive 30 minutes block. The 30 min DIP is sliding
consecutively with 10 min sub-interval has been used.
8.13.9 The Commission observes that per provisions under State Grid Code and IEGC,
measurement period for the purpose of energy accounting, recording of the demand,
scheduling and despatch of power is “time block” which is defined as “time-block’means
a time block of 15 minutes, for which specified electrical parameters and quantities are
recorded by special energy meter, with first time block starting at 00.00 hrs”. There are 96
time-blocks in a day, starting from 00:00 hours with each time-block of consecutive 15-
minute duration. Thus, 30 minute measurement for the purpose of energy accounting,
scheduling and despatch comprise fixed duration from start of hour boundary to next half
hourly boundary and does not envisage any sliding scale for measurement of any 30-minute
duration, as proposed by MSEDCL for energy accounting/ deviation
accounting/determination of Under-drawal/over-drawal or under-injection/under-injection
by participants.
8.13.10Further, DSM Regulations notified by MERC and Central Commission as well as recent
notification of the Regulations for Real time market operations has further emphasised this
aspect by recognising odd numbered time blocks and even numbered time blocks for the
purpose of market operations, and trading on power exchange, alongwith introduction of
concept of gate closure. Thus, entire timeframe for the purpose of energy accounting,
scheduling and despatch, deviation accounting, congestion management etc. is aligned with
the concept of “Time-Blocks” which are fixed duration time-block rather than sliding
duration of the time-block. Generating Companies, Distribution Licensees and even Open
Access consumers would be responsible for their energy accounting, deviation accounting
on “time-block” concept of fixed duration as elaborated above. Under the circumstances,
the Commission opines that recording of demand of Direct Consumers of Licensee on
sliding scale of 30-minute duration would not be proper and would in fact tantamount to
discrimination as against open access consumer.
8.13.11Thus, the Commission rejects the MSEDCL proposal for introduction of sliding scale based
measurement of Billing Demand and MSEDCL should continue with existing practice of
recording of Billing Demand on fixed duration of 30-minutes around boundaries of hourly
start and half-hourly start period (viz. 00:00 to 00:30 and 00:30 to 01:00 hrs and so on). As
per General Conditions under Tariff schedule, the Distribution licensee may measure the
Maximum Demand for any period shorter than 30 minute of maximum use, subject to
conformity with the Commission’s Supply Code Regulations, where it considers that there
MSEDCL’s Submission
8.14.1 Petitioner submitted that the Commission in the last MTR Order dated 12th September 2018,
had acknowledged the issue of wilful violation of Contract Demand during 22:00 to 06:00
hours to avail ToD benefits & Load Factor Incentive and observed that
“In order to ensure operation of electricity grid, it is critical that every constituent
of the system acts within its assigned boundaries. Intentional violation of contract
demand limit by individual consumer for its own financial gain may lead to a system
failure, which may affect other consumers.”
8.14.2 Accordingly, the Commission revised the provision and ruled that LF incentives shall not
be available in case of exceeding Contract Demand during night also.
8.14.3 Petitioner further submitted that, as per the Order dated 24th December 2018 in Case No.321
of 2018, the Commission revised the LF incentive formula for PF and unity PF is considered
instead of actual PF.
8.14.4 The concept of LFI was introduced by Hon’ble Commission in Case No. 2 of 2003 i.e.
nearly 16 years ago. Since then till date, there have been numerous disputes with regard to
the interpretation of the LF formula. Consumers are approaching MSEDCL with the
demand of consideration of interruption/non-supply hours and shut down more than 60
Hours because of unforeseen incidents like water logging in EHV Substation, Flood
situation etc. However, as per Formula only planned outage (since 60 hours in a 30 day
month is already in built in the Formula) is considered for reduction in hours for calculation
of Load Factor. This ultimately results into disputes before CGRF or Hon’ble Commission.
8.14.5 Change in LFI computation is sought with the intention of bringing clarity and
simplification in the LFI formula and that any shutdown (planned outage), breakdown or
any interruption of supply to the extent of 60 hours in a month has to be considered while
framing the calculation of Load Factor Incentive which means, in the 60 hours, the effect
of non-supply to the extent of 60 hours is built in and will not have additional effect while
calculating LF whereas any non-supply beyond 60 hours will be considered.
MERC Order – Case No. 322 of 2019 Page 503 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
8.14.6 Since the introduction of LF incentive, in the calculation of Load Factor as per the
methodology adopted by the Commission, 60 hours have been deducted towards
interruption/non-supply in a 30-day month. As per the formula of LFI, maximum incentive
of 15% becomes available at 92.5% which means non-supply including interruption up to
60 hours are inbuilt in the formula.
8.14.7 Petitioner submitted that the 60 hours of non-supply should include any type of breakdown,
interruptions, maintenance, planned shutdowns, etc.
8.14.8 Petitioner further submitted that there is non-supply for more than 60 hours or sometimes
more than a few days due to natural calamities like floods or cyclones. Since lack of clarity
on how to treat planned outages resulted in various disputes, there is a need to bring in more
clarity in the formula for treatment of shutdown or planned outages. Petitioner, thus,
proposed not to deduct any non-supply upto 60 hours including planned shutdown for
calculating the load factor, whereas, any non-supply of more than 60 hours will be deducted
while calculating the load factor as per the following formula proposed by the Petitioner:
Load Factor = Consumption during the month, in MU
Maximum Consumption possible during the month, in MU
In case the consumer exceeds its contract demand in any particular month, the Load
Factor Incentive will not be payable to the consumer in that month
8.14.9 Petitioner also submitted that the 60 hours may be reduced to Zero hours by reducing the
incentive and actual non-supply hours shall be excluded from computation of Load Factor,
if the Commission deems fit. This will protect the consumer interest as he will not lose the
incentive due to non-supply from MSEDCL/MSETCL since Load Factor incentive will be
based on performance of consumer, thus reducing litigations.
8.14.10Petitioner asserts that the Load Factor of the consumers will improve due to such revision
and many consumers presently not getting the load factor incentive may get the incentives
for load factor achievement.
8.14.11Petitioner also submitted that in both the proposed cases as above, the maximum incentives
shall be limited to 7.5% and the proposed applicability of Load Factor incentive is as follows
:
• Load Factor above 75% and up to 85% - incentive of 0.25% on the energy charge
for every 1% rise in load factor from 75% to 85%.
• Consumers having load factor above 85% - incentive of 0.50% on the energy charge
for 1% rise in load factor from 85%.
• The total incentive will be subject to a ceiling of 7.5% of energy charges applicable
to the consumer.
Consumption
Total number of
during month CD (kVA) PF
hours during month
(Units)
1 2 3 4 5=1+2+3+4 6 7 8 9
8.14.13As per the existing tariff of MSEDCL, Load factor incentive is available for incentivising
the bulk consumers in the State availing higher loading as compared to the Contract Demand
thereby maintaining a steady demand on the system. Maximum incentive payable is 15%
8.14.16In addition, with AMR/MRI enabled meters being installed to all HT consumers, actual
hours of interruptions are recorded in meter and are readily available at the time of
processing of monthly bill. Hence, in order to compute correct Load Factor, the Commission
has modified the formula and has included the actual interruptions hours recorded in the
meter instead of provision for 60 hours. In case of faulty meter where interruptions hours
are not recorded in the meter, the interruptions hours recorded on feeder meter shall be
considered for calculation of Load Factor Incentive for the individual consumer
MSEDCL’s Submission
8.15.1 Petitioner in its MTR petition proposed to provide incentive to the existing HT consumers
for incremental consumption, with a rebate of Rs.1/kVAh in energy charges for additional
consumption over a threshold limit, provided the effective variable charge of such consumer
should not be less than Rs.4/kVAh after considering all charges, rebates, incentives, etc.
8.15.2 Petitioner submitted that the Commission in its MTR Order dated 12th September 2018 has
observed that encouraging incremental consumption by way of discount would be good in
surplus power scenario and contracted capacity is available in excess which otherwise
would be subjected to backing down. However, the Commission further states that
MERC Order – Case No. 322 of 2019 Page 506 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
providing such rebate during MTR review process would not be proper and hence the same
can be considered along with next filing for new Control Period with detailed scheme and
cost/benefit analysis of such scheme.
8.15.3 Petitioner further submitted that, the Commission in Regulation 81.4 of MYT Regulations
2019 provides for such rebates, “The Distribution Licensee may propose other rebates for
inter-alia, taking supply at higher voltage, bulk consumption, power factor, etc. as apart of
their petition and the revenue impact of the rebates shall be passed on through the Aggregate
Revenue Requirement and tariffs, subject to the Commission’s approval.” However, this
rebate should not be considered under the Regulation 81.5 of the MYT Regulations 2019.
Petitioner requested the Commission to allow this rebate as a part of the ARR. The impact
assessment of incremental consumption, estimate of eligible consumer/consumption base
etc. have been illustrated below:
FY FY FY FY
FY
Cost benefit analysis UoM 2020- 2021- 2022- 2023-
2024-25
21 22 23 24
Net ABR for HT consumers Rs./Unit 8.12 8.31 8.49 8.66 8.81
8.15.4 Petitioner submitted that, it would get additional revenue for incremental sales due to such
subsidising consumers.
8.15.5 Petitioner proposed to provide incentive to HT consumers for incremental consumption with
a rebate of Re.1/kVAh in energy charges for additional consumption over a fixed threshold
but the consumers have to pay the fixed and wheeling charges as may be applicable to that
category. The criterion for allowing the rebate shall be as under:
• The rebate shall be given only to those consumers who source their entire power
from MSEDCL.
• The rebate shall be for a period of 5 years subject to reconsideration during the
MTR.
• The rebate shall be allowed to consumers who consume power above threshold
limit. The total consumption in financial year FY 2018-19 by the consumer shall be
considered as baseline consumption.
• In case, period is less than one year, baseline consumption shall be worked out on
prorate basis.
• The billing at the reduced rates after allowing the rebate shall be done once the
consumer crosses the baseline consumption. E.g. If a consumer’s total annual
consumption in FY 2018-19 was 10,000 units, the consumer shall be entitled for the
rebate of Rs.1/kVAh for consumption exceeding consumption of previous year (not
below the baseline consumption of 10,000 units) in FY 2020-21 onwards.
• The amount of rebate shall be adjusted in the consumer’s bill after completion of
the financial year
• The rebate shall be over and above the existing rebates subject to the fact that the
consumer’s total variable charges should not be less than Rs.4/ kVAh after
accounting all applicable rebates.
• The rebates would also be applicable to Open Access consumers who shift their
entire demand to MSEDCL
8.15.6 Petitioner submitted that such incentives on incremental consumption is prevalent for
industrial, non-industrial and shopping mall categories in Madhya Pradesh and the relevant
clause (3.12 – xii of MPERC Tariff Order FY 19-20) for the same is reproduced as “A rebate
of Re.1 per unit energy charges is applicable for incremental monthly consumption w.r.t
corresponding month of FY 2015-16.”
8.15.7 Petitioner submitted that in order to reduce the burden of fixed charges on its consumers,
there is a need to promote consumption from MSEDCL. Petitioner will also get additional
revenue from the subsidising HT categories apart from optimum utilisation of all sources of
power. Petitioner further submitted that benefit of increased revenue as a result of increased
consumption will get passed on through tariffs during future truing up which will be a win-
win situation for all stakeholders including consumers. Petitioner, thus, requested the
Commission to approve the above proposal and consider the said rebate as a part of ARR.
8.15.8 The Commission notes the submission and rationale provided by MSEDCL for offering
rebate for incremental consumption. With surplus contracted energy available at its
disposal, the Commission agrees with MSEDCL about exploring avenues for increasing
sales within its distribution area as well as opportunities of surplus trading of power through
power exchanges and inter-utility exchange within state. In addition any incremental
consumption by existing or future consumers would help MSEDCL gainfully utilise surplus
/stranded power generation/contracted capacity available with it instead of backing down.
So long as the opportunity for revenue recovery from such sources exceed the
variable/incremental cost of sourcing of such power, it would only benefit MSEDCL to
reduce burden of surplus/stranded power capacity. In that sense, offering such rebate for
incremental consumption to direct consumers as well as open access consumers would be
in order, since aim for offering such rebate is to increase incremental consumption/sale by
Licensee. Hence, the Commission opines that offering such rebate for incremental
consumption to all consumers including partial open access consumers, subject to clearly
laid out conditions would be appropriate.
8.15.9 In this context, the Commission observes that Regulation 81.4 of MYT Regulations 2019
allows for provisioning of such rebates,
“The Distribution Licensee may propose other rebates for inter-alia, taking supply
at higher voltage, bulk consumption, power factor, etc. as a part of their petition
and the revenue impact of the rebates shall be passed on through the Aggregate
Revenue Requirement and tariffs, subject to the Commission’s approval.”
MERC Order – Case No. 322 of 2019 Page 509 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
8.15.10Thus, as covered under earlier sections, impact of such rebate has been estimated based on
sales projections with some assumptions to be recovered as part of ARR component in line
with regulatory accounting treatment given in case of discounts/prompt payment rebate etc.
8.15.11Thus, in line with the MSEDCL’s Proposal and Commission’s view on allowing rebate for
incremental consumption with certain modifications to MSEDCL’s proposal, the
Commission in principle accepts the proposal of MSEDCL. The rebate for incremental
consumption is allowed @ Rs 0.75/KVAh and further, it needs to be ensured that conditions
and operational modalities are laid out clearly to avoid any discrimination and potential
litigations are minimal.
• The rebate shall be given to eligible consumers including partial open access
consumers falling under above consumer categories to the extent of procurement
from MSEDCL.
• The rebate shall be for a period of 3 years subject to reconsideration during the
MTR.
• The rebate shall be allowed to eligible consumers who consume power above
threshold limit.
• In case of a consumer registered into system for duration lower than 3 years, such
consumer shall be eligible for availing incremental rebate from the next billing cycle
upon completion of 3-year period and average monthly consumption for past three
years shall be considered as its baseline consumption (or monthly threshold
• The billing at the reduced rates after allowing the rebate shall be done on monthly
basis subject to condition that net entitlement for the rebate under this head of
incremental consumption shall be determined on annual basis (April to March)
equal to energy units consumption in excess of baseline consumption (i.e. annual
threshold consumption). The adjustment for shortfall/excess in case cumulative
monthly consumption for the yearly consumption vis-à-vis its baseline consumption
(i.e. annual threshold consumption) shall be effected in the last monthly (for March)
billing period. No carry-forward of shortfall/excess shall be allowed from one year
to next year.
Provided that such adjustment of rebate for yearly incremental consumption vis-à-
vis baseline consumption (i.e. annual threshold consumption) shall be undertaken
from FY 2021-22 onwards and no such adjustment shall be undertaken for FY 2020-
21 wherein monthly rebate shall continue considering emergent situation arising in
FY 2020-21 due to global pendemic of COVID-19 and its possible fall out on annual
electricity consumption by industry and society at large.
• For example, If a consumer’s 3-year average annual consumption in was 12,000
units, the consumer shall be entitled for the rebate of Rs.0.75/kVAh for consumption
exceeding its monthly threshold consumption (not below the baseline consumption
of 1,000 units per month) in FY 2021-22 onwards. However, in case its cumulative
monthly consumption for the yearly period falls short of annual threshold
consumption of 12,000 units then, consumer shall not be entitled for incremental
consumption rebate for that financial year and shortfall (or rebate already availed
by consumer in earlier months, if any) shall be adjusted for recovery in monthly
billing period for March.
• The Commission has not considered isolated cases which may become Permanently
Disconnected during the year in which a rebate has been availed for some months.
The details of such cases, if any will be dealt based on the data as may be submitted
by MSEDCL during MTR.
MERC Order – Case No. 322 of 2019 Page 511 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
• The rebate shall be over and above the existing rebates subject to the fact that the
consumer’s total variable charges should not be less than Rs.4/ kVAh after
accounting for all applicable rebates.
8.16.1 During public hearing, many industrial consumers have voiced concerns regarding high
tariff regime prevalent in the state in comparison to other states for similarly placed
industries. They have also highlighted their bulk consumption offers significant revenue
stability to Utility as also other benefits in terms of power procurement planning and load
generation balancing by Utility. With expected increase in demand charges and likely
revision in billing demand their cost of operations where electricity is major raw material
source affects the economics of their operations significantly. Hence, such
industries/stakeholders have vehemently argued their case for bulk consumption discount
or rebate.
8.16.2 The Commission observes that out of around 14000 number of HT-Industrial consumers,
around 0.4% no. of consumers consume > 5 MU/month and contribute around 25% of total
consumption of HT-Industrial category. Further, around 3% no. of consumers consume
between 1 to 5 MU/month and contribute around 29% of total consumption of HT-Industrial
category and around 22% no. of consumers consume between 0.1 to 1 MU/month and
contribute around 39% of total consumption of HT-Industrial category. The Commission
opines that bulk consumption rebate with a reverse telescopic slab would benefit all such
consumers under HT-Industrial consumers with consumption in excess of 1 lakh units per
month (0.1 MU per month). Thus, the Commission has decided to introduce “Bulk
Consumption” rebate in a reverse telescopic manner for HT-Industrial consumers in
following manner:
8.16.3 Bulk Consumption Rebate shall be applicable on the Energy Charge component including
MERC Order – Case No. 322 of 2019 Page 512 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
8.16.4 In this context, the Commission observes that Regulation 81.4 of MYT Regulations 2019
allows for provisioning of such Bulk Consumption rebates,
“The Distribution Licensee may propose other rebates for inter-alia, taking supply
at higher voltage, bulk consumption, power factor, etc. as a part of their petition
and the revenue impact of the rebates shall be passed on through the Aggregate
Revenue Requirement and tariffs, subject to the Commission’s approval.”
8.16.5 Thus, as covered under earlier sections, impact of such rebate has been estimated based on
sales projections with some assumptions to be recovered as part of ARR component in line
with regulatory accounting treatment given in case of discounts/prompt payment rebate etc.
8.16.6 Illustration:
8.16.7 Say a consumer consumes 15 MU during month then, its consumption more than 1 Lakh
units upto 1 MU units rebate will be 2%/unit, for next 4 MU (i.e. upto consumption of 5
MU) rebate will be 1.5%/unit and for consumption in excess of 5 MU upto 15 MU, rebate
will be 1%/unit.
MSEDCL’s Submission
8.17.1 MSEDCL submitted that it was difficult to persuade consumers to shift to prepaid metering
in the absence of any discount. Further, activities like meter reading, preparation and
distribution of bills and payment collection takes considerable time and the costs associated
with such processes is a significant amount that is being charged to the consumers which
will decrease if consumers opt for prepaid meters. In view of this, the Commission in its
Tariff Order as dated on 12th September 2010 (in Case No.111 of 2009) has approved
prepaid meter rebate of 5%.
8.17.2 Petitioner submitted that the consumers paying regular bills within the stipulated timelines
get Prompt Payment Discount of 1%. Petitioner further submitted that the Commission
provides interest for normative working capital at a rate of about 8-10% p.a. which is less
than 1% per month. The Commission provides interest for security deposit at bank rate
which is about 6-6.5% p.a. The interest rates provided for bank deposits are also in the range
of 6-8% p.a. Petitioner also submitted that in view of the same, existing discount of 5% is
much higher which comes to 60% p.a. which was initially given as promotional activity and
there is a need to correct the same.
8.17.3 Petitioner proposed to reduce the prepaid meter rebate to 2% of the consumer’s total
monthly bill as the existing rebate appears quite high considering the saving in cost from
implementation of prepaid meters. Petitioner also submitted that even after reduction of 2%,
it is still attractive and higher than prompt payment discount.
8.17.4 Petitioner, thus, requested the Commission to allow the Prepaid Meter Rebate as proposed
above.
8.17.5 The Commission has sought the detailed rationale of MSEDCL’s proposal of reducing the
existing prepaid meter rebate as part of data gaps, to which the response of MSEDCL was
not found sufficient enough to justify its claim of reducing the rebate for prepaid meters
from 5% to 2%.
8.17.6 In addition, the Commission has also sought the details of category wise prepaid sales as
part of data Gaps, the details of the same is provided in the following table:
Table 8-26: Category wise prepaid sales
FY 2016-17 FY 2017-18 FY 2018-19
LT Prepaid
11372 10.77 10,528 9.59 9,438 7.75
Res,
LT- Prepaid
1693 1.14 1557 0.97 1358 0.70
Comm.
LT- Prepaid
6 0.00 12 0.00 13 0.00
Temp.
8.17.7 From above table, it is clear that, the overall sales of LT prepaid meter sales is very
miniscule to have any significant impact on overall ARR which necessitates review of
rebate for prepaid from current level of 5% to 2%. In addition, there is a y-o-y reduction in
the Prepaid meter sales, reducing the existing rebate from 5% to 2%, will further de-
motivate the consumer who wish to opt for prepaid connections. Thus, the Commission has
MERC Order – Case No. 322 of 2019 Page 514 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
8.17.8 The Commission has already approved the capital cost for release of Ag connection on
HVDS. The Capital cost involved in releasing Ag connection under HVDS is relatively
costly compared to realigning the same on LT level. The Commission also agrees with the
advantages of the HVDS system in terms of reliability and quality of supply to the Ag
consumers. The Commission also agrees with MSEDCL that with all associated advantage
and higher investments, there is a clear expectation of MSEDCL to received timely
payments. The higher capital cost is socialized on all the consumers. The Commission
directs MSEDCL that all the HVDS connections shall be released through prepaid meters
only. Also, HVDS Ag connections released earlier should also be converted into prepaid
meters within 6 months. Also, in case of non-availability of prepaid meters, the released
connections should be converted to prepaid meters within 6/12 months.
MSEDCL’s Submission
8.18.1 MSEDCL submitted that the Commission in its Order dated 14th June 2019 had directed
the Petitioner to submit details of revenue collected on account of transmission charges from
partial OA consumers for the period of FY 2016-17 to FY 2019-20 in its next tariff petition.
Accordingly, the Petitioner submitted the details of transmission charges collected from
partial OA consumers in the following table:
Table 8-27: Transmission charges collected from partial OA
Particulars Amount in Rs. Crores
FY 2016-17 284.82
FY 2017-18 220.17
8.18.2 Petitioner submitted that the Distribution Licensees may be allowed to retain the
transmission charges collected from partial OA consumers as the demand from partial OA
consumers is embedded within the demand of the Licensee. Hence, the transmission charges
payable by the Distribution Licensee also includes the share of transmission charges
attributable to partial Open Access consumers which the Distribution Licensee must recover
from partial OA consumers to avoid any burden on regular consumers.
8.18.3 Petitioner further submitted that the CPD/NCPD of Distribution Licensee should be
exclusive of the open access capacity of partial OA consumers while calculating the Base
TCR of the Distribution Licensee for determination of InSTS charges. This will ensure
correct transmission charge liability of the Distribution Licensees corresponding to their
own consumers since, by including open access capacity for partial OA consumers, STU is
getting paid double for the same demand. Following table provides details of partial open
access consumers and its impact on the Petitioner:
Table 8-28: Transmission charges- details of partial OA
Particulars Unit FY 16-17 FY 17-18 FY 18-19
8.18.4 Petitioner requested the Commission to allow it to retain the transmission charges collected
from partial OA consumers. Petitioner further requested the Commission to devise a
mechanism to recover the complete amount of transmission charges due to OA consumers.
Petitioner submitted that it has raised this issue several times before the Commission
through submissions in petition and comments on Draft Open Access Regulations.
8.18.5 The Commission has already discussed its detailed dispensation of not allowing MSEDCL’s
claim of retaining Transmission Charges collected on behalf of STU in the ARR sections
above and accordingly the impact of the same have also been disallowed in the respective
year’s ARR.
8.18.6 Besides, the Commission has also issued directions for passing on the earlier retained
revenue from transmission charges collected from partial open access consumers during FY
2017-18 to FY 2019-20 to be passed onto STU in a time-bound manner. The reduction in
Non-tariff income and increase in ARR to that effect has already been given effect to
through this Order. Further, benefit of such passing on of transmission charge revenue
would also be available to MSEDCL, (being TSU), as part of sharing of Intra-state
transmission system cost (TTSC) in proportion to its share in TTSC.
8.19 kVA based Fixed Charges for loads < 20 kW & load in kVA instead of kW
MSEDCL’s Submission
8.19.1 Petitioner submitted that at present tariff is categorised as per the Sanctioned load in kW,
for categories such as LT commercial, LT Public services and LT industrial, the fixed
charges for 0-20 kW are based on Rs./Connection/Month while the consumers above 20
kW in these categories are billed on the contract demand basis (kVA) of the consumer i.e.
Rs./kVA/month. Hence, it is necessary to divide categories as per Contract Demand of the
consumer. Following cases highlight the necessity for contract demand as a basis for
categorisation.
• Case 1: - If consumer having 20 kW sanctioned load uses the same load at 0.7 PF,
then the demand of the consumer will be = 20/0.7 = 28.57 kVA
• Case 2: - If consumer having 25 kW sanctioned load uses the same load at unity PF,
then the demand of the consumer will be = 25/1 = 25 kVA
8.19.2 Petitioner submitted that, in Case 1, the consumer uses more Contract Demand than Case 2
but still gets billed at only Fixed Charge of Rs. /connection/month because sanctioned load
is below 20 kW. Hence it is necessary to correlate slabs of tariff in kVA also.
8.19.3 Petitioner suggested that the sub slabs in the 3 phase LT categories need to be on the basis
of kVA only and based on the recorded demand, the consumer shall be billed on
Rs./kVA/month for that month and if the consumer crossed the 20 kVA limit on three
instances in a year, he shall be categorised in higher slab permanently. Petitioner submitted
that; the Commission has given similar ruling in the Order dated 1st January 2019 in Case
No.60 of 2018.
8.19.4 Petitioner further submitted that if the consumer is willing to reduce the demand back to its
previously allocated demand, then it would monitor the load of the consumer for 3
consecutive months before switching it back to the previously allocated lower tariff
category. Further, all consumers shall be charged for minimum demand of 1 kVA even if
the consumer’s demand is below 1 kVA.
MERC Order – Case No. 322 of 2019 Page 517 of 752
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of ARR for FY 2020-21 to FY 2024-25
8.19.5 Petitioner submitted that it shall continue to levy fixed charges on Rs./connection/month as
per the proposed tariff for consumers having single phase connections (upto 40 Amp/7.5
kW) in 0-20 kVA industries, commercial, public services in LT category. Petitioner thus,
requested the Commission to allow the kVA-based demand charges for LT category as
proposed above.
8.19.6 The Commission has noted the submissions of MSEDCL, and is of the view that, the
proposed billing based on the Contract Demand for 3-Phase LT consumers between 0-20
kW cannot be implemented at this stage, since, the Commission is not yet sure of the
readiness of MSEDCL and also MSEDCL needs to carry out a detailed study about the
likely impact of implementation of this proposal. The Commission would not like to take
any hasty step that may result in the tariff shock for such consumer categories at the same
time, it is also important to assess the potential impact on number of consumers alongwith
their connected load. In earlier sections, the Commission has already dealt with issue of
Tariff design for consumers < 20 kW including feasibility of extending kVAh billing in
phases, likely impact of revision in Fixed/Demand Charges for such low end consumption
basket but affecting vast number of consumers. A comprehensive study on these aspects
would be necessary before redesigning tariff aspects for such consumer categories.
8.19.7 Thus, the Commission has not allowed proposed claim of MSEDCL in this Order.
MSEDCL’s Submission
8.20.1 Petitioner submitted that it has always supported renewable energy and its current RE
contracted capacity is 10795 MW and installed capacity is 7654 MW which is one of the
highest in the country.
8.20.2 Petitioner submitted that it encounters challenges due to continuous addition of rooftop RE
systems as installation of such facility not only reduces the utilisation of its distribution
network but also disturbs the power planning and results into stranded tied-up capacity of
generation. Net metering consumers end up paying much lower charges for keeping ready
the network and generation capacity which was earlier setup/ tied up for all consumers
including these (rooftop) consumers while the burden of unrecovered expenses falls on
other consumers of MSEDCL.
MERC Order – Case No. 322 of 2019 Page 518 of 752
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of ARR for FY 2020-21 to FY 2024-25
8.20.3 The solar energy is generated during daytime and after self-consumption by the consumer,
the balance energy is fed into the grid. Due to its combined impact, the utility has to back
down thermal generation but is obligated to pay same fixed cost to generators. When there
is no solar power generation (evening, seasonal change, technical problem in the system,
etc.), the rooftop consumer draws full power as per the requirement from the grid and utility
has to keep network and generators on bar ready to feed this demand. The rooftop consumer
is using the grid as a storage system for his solar rooftop arrangement under the net metering
and at the same time, loading the balance costs on other consumers of the distribution utility
such as generators fixed cost, infrastructure cost recovery, CSS etc. Thus the burden of such
unrecovered expenses from net metering systems falls on other consumers of MSEDCL.
8.20.4 Petitioner further submitted that the net metering facility is being utilised by the high end
HT/LT consumers which are subsidising consumers and the event of any decrease in
consumption by these consumers from Distribution Licensee will have a direct impact by
way of increase in tariff for all consumers due to under recovery. Thus, Cross subsidy
balance inbuilt in the tariff structure will get disturbed.
8.20.5 Petitioner submitted that the Commission has provided for levy of Grid Support Charges on
the generated energy under the net metering systems in the MERC Grid Interactive Rooftop
Renewable Energy Generating systems Regulations 2019.
8.20.6 Petitioner submitted that as per the Net Metering Regulations 2019, the Grid Support
Charges cover balancing, banking and wheeling cost after adjusting RPO benefits avoided
distribution losses and any other benefits accruing to the Distribution Licensee.
8.20.7 Petitioner submitted that the fixed cost component of its cost gets recovered partially
through demand/fixed charges. However, the variable charges along with the fixed cost
component built into it remains unrecovered. Petitioner further submitted that it shall save
only variable component of power purchase cost and T&D losses due to consumer opting
for net metering arrangement. Petitioner proposed Grid Support Charges for rooftop net
metering arrangements considering the category-wise variable charges, marginal variable
cost of power purchase, applicable wheeling and intra state transmission losses. Petitioner
has shown the computation for FY 2020-21 in the following table:
Table 8-29: Proposed Grid Support Charges for Rooftop Net Metering Arrangements
(FY 2020-21)
Marginal
Intra state Grid
Variable cost of Wheeling
Category transmission Support
charge power loss
loss Charge
purchase
HT I: HT – Industry
HT II: HT – Commercial
HT III: HT –
Railways/Metro/Monorail traction
HT V(A): HT – Agricultural
Pumpsets
Marginal
Intra state Grid
Variable cost of Wheeling
Category transmission Support
charge power loss
loss Charge
purchase
HT X: HT – Electric Vehicle
Charging Station
Marginal
Intra state Grid
Variable cost of Wheeling
Category transmission Support
charge power loss
loss Charge
purchase
LT Residential
LT I(B): LT – Residential
(B) > 20 kVA and ≤ 50 kVA 10.65 3.38 3.74% 12.00% 6.66
(B) > 20 kVA and ≤ 50 kVA 4.75 3.38 3.74% 12.00% 0.76
LT V(A): LT – Industry –
Powerlooms
(ii) > 20 kVA and ≤ 50 kVA 5.65 3.38 3.74% 12.00% 1.66
(ii) > 20 kVA and ≤ 50 kVA 8.25 3.38 3.74% 12.00% 4.26
8.20.8 Following table provides the category wise and year wise proposed Grid Support Charges
for Rooftop Net Metering Arrangements
Table 8-30: Grid Support Charges for Rooftop Net Metering Arrangements
(H T Category)
FY 2020- FY 2021- FY 2022- FY 2023- FY 2024-
Category
21 22 23 24 25
HT I: HT – Industry
HT II: HT – Commercial
HT III: HT –
Railways/Metro/Monorail traction
HT V(A): HT – Agricultural
Pumpsets
HT
EHV
HT
EHV
HT X: HT – Electric Vehicle
Charging Station
Table 8-31: Grid Charges for Rooftop Net Metering Arrangements (LT category)
FY 2021- FY 2022- FY FY 2024-
Category FY 2020-21
22 23 2023-24 25
LT Residential
LT I(B): LT – Residential
1 – 100 units
(B) > 20 kVA and ≤ 50 kVA 6.66 6.86 7.03 7.19 7.33
(A) 0 – 20 kVA
LT V(A): LT – Industry –
Powerlooms
(i) 0 – 20 kVA
(ii) > 20 kVA and ≤ 50 kVA 1.66 1.76 1.83 1.89 2.03
(ii) > 20 kVA and ≤ 50 kVA 4.26 4.56 4.83 5.09 5.33
8.20.9 Petitioner requested the Commission to approve the levy of Grid Support Charges on
generated energy for Net Metering systems as proposed above.
8.20.10Petitioner submitted that the Grid Support Charges for rooftop Net Metering arrangements
shall vary depending on:
• Any cost approved by the Commission for Genco/Transco in their respective Tariff
orders or by way of a separate order
• Petitioner’s REC requirement to fulfil the shortfall in meeting the RPO targets
8.20.11Petitioner submitted that, the RPO benefits, being a variable element, shall be adjusted at
the year-end i.e. at the time of settlement of banked units and after assessment of REC
requirement, as per the actual monthly REC rates and consumption during the respective
month and financial impact of net metering of below 10 kW consumers.
8.20.12Petitioner submitted that the benefit of RPO (REC rate) shall be as per the prevailing market
rates. Petitioner further submitted that in case it does not require the energy for RPO
fulfilment, the benefit of RPO to net metering consumers shall be treated as Zero and the
benefit shall be adjusted only till the time the Petitioner has RPO shortfall. Further, if the
consumer is an obligated entity (above 1 MW), then also RPO benefit for that consumer
shall be treated as Zero.
8.20.13Petitioner further submitted that the Net metering Regulations 2019 provides that the
consumers having sanctioned load up to 10 kW shall be exempted from the payment of Grid
MERC Order – Case No. 322 of 2019 Page 527 of 752
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of ARR for FY 2020-21 to FY 2024-25
Support charges for net metering systems. Petitioner also submitted that the loss for
exemption from paying the Grid Support charges needs to be recovered from consumers
having sanctioned load above 10 kW so as to avoid burden on consumers not opting for net
metering. This impact shall be computed by considering the same category wise GSC as
proposed above and shall be passed on to >10 kW net metering consumers during the year-
end settlement as proposed in the above paragraph.
8.20.14Petitioner submitted that it has computed Grid Support charges for all categories as per the
above table and assumptions. However, certain categories such as LT Residential (0 – 100
units), LT PWW (>20 kVA upto 50 kVA), LT AG Metered Others, LT Temporary Supply
Religious, LT Crematoriums and Burial Grounds, LT Public Services – Govt. (0 – 20 kVA)
and HT AG Pumpsets & HT Temporary supply Religious, considering the adjustment of
RPO benefits and floor price of Re.1.00/unit of REC, such charges may be Nil. Petitioner,
hence, has not proposed Grid Support Charges for these categories in the petition, however,
the same shall be reviewed in the MTR process.
8.20.15Petitioner further submitted the applicability of Grid Support Charges for rooftop net
metering arrangements as follows:
RE generated units Applicable charges
8.20.17Petitioner proposed that no Grid Support Charges will be levied for rooftop RE systems
with Net Billing arrangement.
8.20.18Petitioner submitted that the financial impact of the Grid Support Charges is not considered
at present due to uncertainty of usage by consumers but the impact on revenue for such
charges will be considered at the time of final true up.
8.20.19The Commission notes the submission made by MSEDCL. However, the Commission also
notes that this proposal of introduction of Grid Support Charges was the most prominent
issue highlighted to the Commission during the public consultation process of this Petition.
It had received several written and oral objections on the issue which are captured in brief
in chapter 2 of this Order. As a general principle the Commission wants to promote solar
generation to the extent possible and has acted upon by way of notifying the RPO
Regulations where the solar targets have been increased and further an incentive is available
for exceeding the solar target. Having said this, and considering the complexity of the issue
of Grid Support Charges, the Commission highlighted following issues for analysis
covering the following aspects:
8.20.20The first two aspects viz. Effect of Net-metering on Utilities and on consumers and
assessing technicality of introduction of Grid Support Charges have been well elaborated in
its Statement of Reasons of the Net metering Regulations, 2019 along with detailed
rationale. While, the Commission in the said Regulations has provided various benefits for
facilitation of net metering based solar roof-top systems, the difficulties on the side of Utility
due to net-metering due to increased proliferation of such systems in the distribution grid
was also highlighted. The relevant extract of the statement of reasons is reproduced as
under:
“Further, the existing structure of Retail Supply tariff has an in-built cross-subsidy
component. The Tariff for cross-subsidizing categories, such as Commercial,
Industrial, etc., is higher than the Average Cost of Supply (ACoS) and the Tariff of
cross-subsidised categories such as Residential and Agriculture, is lower than
ACoS. In short, the higher Tariff for Commercial and Industrial categories cross-
subsidises the lower Tariff for Residential and Agriculture category. Any revenue
MERC Order – Case No. 322 of 2019 Page 529 of 752
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of ARR for FY 2020-21 to FY 2024-25
loss due to lower sales billed to Commercial and Industrial consumers setting up
Rooftop RE Plants would have to be met through tariff increase to subsidised
consumer categories and other subsidising consumers, who do not have the space
or capital to invest in Rooftop RE plants.
Further, the generation from distributed RE sources such as wind and solar is non-
firm. Because of uncertainty of generation from these sources, the power
procurement plan of the Distribution Licensee is required to be dynamic and is likely
to be adversely affected. Also, Rooftop RE sources are grid connected and operating
in integration with the distribution grid. The balancing of the grid is required to be
done at distribution system level, considering non-firm RE generation. The
responsibility of grid management and the Deviation Settlement Mechanism lies
with the Distribution Licensees, and the rooftop RE systems do not have such
responsibility.
Also, the supply of Distribution Licensee works as standby arrangement for such
grid-connected systems, which will always be available in case of failure of
generation from these sources.
Further, generation from RE sources is exported to the distribution grid during
periods of lower self-consumption and could be taken back from distribution grid
during peak period/higher consumption period. Thus, the distribution grid is being
used for free as a bank/battery to store the energy generated, which is taken back
for consumption. The consumer also saves on the requirement and capital cost of
battery systems and their related inefficiency, which would have to be installed, in
case the banking facility was not provided by the Distribution Licensee. The
consumer does not have to match his generation capacity to his consumption pattern
and has the luxury of generating and injecting into the grid, with the facility to utilise
such energy at no cost at any time during the financial year.
Also, export of generation into distribution grid during light loaded conditions
would lead to increase in voltage of distribution system at local level. The voltage
levels are required to be maintained by the Distribution Licensee at specified level
as per applicable Regulations. Thus, higher penetration of Net Metering
installations affects the technical operations of the distribution grid.
Under the Net Metering Arrangement, there is saving to consumer equal to
applicable energy charges for every unit generated from the rooftop RE System. The
saving increases with the increase in applicable tariff, i.e., the level of cross-subsidy.
In other words, the Return on Investment in rooftop RE systems is artificially higher
because of the cross-subsidy element present in the tariff for the respective category.
The Commission has been reducing the cross-subsidy over the years, and will be
continuing in its efforts to do so over the future tariff determination exercises.
Therefore, the Return on Investment will reduce as the tariff reduces.
On the other side, there is revenue loss equal to applicable tariff for every unit
generated from the rooftop RE System. Further, the Aggregate Revenue
Requirement (ARR) of the Wires Business of the Distribution Licensee is entirely
fixed cost in nature. However, the recovery of Wheeling Charges in the State of
Maharashtra is entirely variable in nature, as the Wheeling Charges are recovered
in Rs/kWh terms. As the quantum of energy billed to the consumers is reduced under
the Net Metering Arrangement, the Wheeling Charges will also be under-recovered
to that extent. Similarly, a major part of the fixed cost of the Distribution Licensee
is recovered through energy charges levied by the Distribution Licensee. In case
of MSEDCL, the Fixed Charges are designed to recover only one-third of the Fixed
Costs of MSEDCL. Hence, any reduction in units billed due to Net Metering, would
lead to lower revenue from energy charges, further leading to increased under-
recovery of fixed costs of the Distribution Licensee.
At the same time, Net Metering is not entirely disadvantageous to the Distribution
Licensee. The Distribution Licensee is able to meet its RPO targets on account of
the units deemed to have been purchased from RE sources, for all units adjusted
against the consumers’ bills due to Net Metering. Further, reduction of every unit
of sale leads to lower power purchase requirement to that extent, which will result
in corresponding savings in variable cost of power purchase. It has to also be noted
that this saving in power purchase quantum is at consumption end, thereby leading
to increased saving in power purchase quantum at the Generator busbar, after
factoring in the Transmission Losses and Distribution Losses. Further, due to the
very nature of distributed generation located at consumption end, the Distribution
Losses would also reduce, though it could be difficult to quantify the exact benefits
in this regard.
From the above, it can be seen that the role of the Distribution Licensee is crucial
in facilitating the operation of the Net Metering Arrangement. Hence, it is required
to balance the interest of both consumers as well as the Distribution Licensee.
(Emphasis Added)”
8.20.21Considering the pros and cons as highlighted above, the intent of the Commission was clear
as stated in the later part of the aforementioned paragraph i.e., to strike a balance of the
interest of both consumers as well as Distribution Licensee. Hence the need for introduction
of such charges is established. Moreover, during the public hearing, various entities, and
consumer groups including the Prayas Energy Group, Vidarbha Industries association had
supported the concept of Grid support charges. However, what is demanded by various
stakeholders is the reasoned, rationale principles for determination of such Grid Support
Charges and thereby ensuring regulatory certainty regarding the same. This is a very fair
expectation.
MERC Order – Case No. 322 of 2019 Page 531 of 752
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of ARR for FY 2020-21 to FY 2024-25
Legal Tenability
8.20.22In this context, the Commission would like to highlight that determination of Grid Support
Charges is in pursuance of the provisions for such determination as specified under its Net
metering Regulations, which is statutory in nature. Thus, the levy of such charges is legally
tenable in accordance with the provisions of the said Regulations formulated and in exercise
of the powers conferred to Commission under Sections 86(1) (e) and 181 of the Electricity
Act, 2003 upon following due regulatory process for notification of the same.
8.20.23Net metering Regulations, 2019 define the principle based on which Grid Support charges
have to be determined. It specifies parameters to be considered while determination of such
charges such as balancing cost, banking and wheeling cost giving due adjustment for
parameters such as RPO benefits, avoided distribution losses and any other benefits
accruing to the distribution licensee. The relevant extract of the Regulations is reproduced
as under.
11.5 The Commission may determine in the retail Tariff Order such Grid Support
Charges to be levied on the generated energy under Net Metering systems which
shall cover balancing, banking and wheeling cost after adjusting RPO benefits,
avoided distribution losses and any other benefits accruing to the Distribution
Licensee. These Grid Support Charges would be determined consumer tariff
category wise, based on the proposal of the Distribution Licensee in its retail supply
Tariff Petition, supported by adequate justification:
Provided that the consumers of all Categories having Sanctioned Load up to 10 kW
shall be exempted from payment of Grid Support Charges for Net Metering systems:
8.20.24Based on the above specified principle, the Commission hereby stipulates the following
formulation for determination of Grid Support Charges separately for HT category of
consumers and LT category of consumers for the gross generation of solar energy:
Grid Support Charges (HT) GSC (HT) = BC+CB+WC(HT)-(RREB+ADL(HT))
Grid Support Charges (LT) GSC (LT) = BC+CB+WC(LT)-(RREB+ADL(LT))
Where,
‘BC’ shall mean the Balancing Cost,
‘CB’ shall mean the Cost of availing Banking facility,
‘WC (HT) & WC (LT)’ shall mean the Wheeling Charges for HT & LT categories
respectively,
‘RREB’ shall mean the Rooftop RE benefit accrued to the Distribution Licensee
‘ADL (HT) & ADL (LT)’ shall mean the Avoided Distribution Loss for HT & LT
categories respectively,
MERC Order – Case No. 322 of 2019 Page 532 of 752
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of ARR for FY 2020-21 to FY 2024-25
8.20.25The premise for determination of values against each of the above identified parameters are
as listed below:
Parameters Premise
Fixed Cost of Thermal Generating Stations which will act
Balancing Cost (BC)
as standby or balancing support
Difference in ToD Charges during day peak when
generation from Solar occurs and banking takes place and
Cost of Banking (CB)
ToD charges of the evening peak when utilization of
banked energy takes place.
Wheeling Charges
Wheeling Charges (HT) As determined in this Order
Wheeling Charges (LT) As determined in this Order
8.20.26The following table shows the working of GSC based on the above parameters.
Workings
Nomenclature Premise
FY 21
Fixed Cost of Thermal Generating Stations which will act
BC
as Standby or balancing support 1.31
a. 2% of banking cost (earlier policy initiative) ~ 0.08 Rs/u
CB b. Diff. in ToD Charges: (1.10 - 0.80) Rs/kWh ~ 0.30 Rs/u
0.08
whichever is lower
WC
WC(HT) As determined in this order
0.57
Workings
Nomenclature Premise
FY 21
WC(LT) As determined in this order
1.45
GSC
GSC(HT) GSC (HT) = BC+CB+WC(HT)-(RREB+ADL(HT)) 1.45
GSC(LT) GSC (LT) = BC+CB+WC(LT)-(RREB+ADL(LT)) 2.33
Approved
Concessional GSC Charges
GSC
Approved
AGSC (HT) 50% of the GSC (HT) 0.72
GSC(HT)
Approved
AGSC (LT) 50% of the GSC (LT) 1.16
GSC(LT)
8.20.27Grid support charges at HT level are lower than that at LT level as cost to serve principle
for allocation of distribution network cost suggests that network related capital costs and
associated support costs of its operation should be allocated amongst HT:LT network
considering the fact that network at HT is used to cater to requirements of HT as well as
LT. Thus, wire cost and wheeling cost at HT are further allocated to LT and thus per unit
cost of wheeling at HT is lower than per unit cost of wheeling at LT. Accordingly, Grid
Support Charges at HT are lower than that at LT voltage level.
8.20.28As per statistics presented by MSEDCL more than 460 MW of RTPV systems (245 MW at
HT level and 215 MW at LT level) have been deployed within MSEDCL area as on January
2020. The Commission notes that said installation is way behind the policy target set by the
Government of Maharashtra. The commercial impact on MSEDCL is commensurately not
significant. Thus, to incentivize installation of RTPV, the Commission has decided not to
impose any Grid Support Charge on RTPV under net-metering arrangement till cumulative
installed capacity of RTPV in the State reaches 2000 MW. Subsequent to that Commission
will reconsider option of imposing Grid Support Charge as provided under the Regulations.
8.20.29Having, exempted levy of Grid Support Charge, the Commission cannot be ignorant of the
fact that Distribution Licensee incurrs certain costs in order to provide services to RTPV
under net-metering arrangement. One of such service is energy banking facility under which
RTPV owner banks excess generated energy with MSEDCL and uses it subsequently.
During public consultation process, some of the stakeholders have suggested that the
Commission may impose banking charges in kind i.e. deduct 15 to 20% of banked energy
as a banking charge. The Commission notes that such units made available by way of
adjustment in kind, can be used for offsetting some of the Wheeling Loss which the licensee
incurrs in supplying back the banked units to consumers. Hence, till the Grid Support
Charges as envisaged in the Regulations stay exempted, in order to enable MSEDCL to at
least recover cost of banking service, the Commission has decided to levy banking charge.
For this purpose, the Commission has linked such Banking Charge to Wheeling Loss
allowed in this Order i.e. 7.5% for HT and 12% to LT. Accordingly, for RTPV connected
on HT network, from the energy injected into the grid, 7.5% energy will be deducted by
MSEDCL as a Banking Charge. Similarly, for RTPV connected on LT side such deduction
of energy would be 12%.
8.20.30In pursuance of the principles specified under Net Metering Regulations, 2019 and in view
of the foregoing, the Banking Charges shall be applicable to all categories of consumers for
future installations of rooftop systems under net metering arrangement to be commissioned
from the date of issuance of this Order in MSEDCL area, except for the following:
• Rooftop PV systems installations Behind the Consumer’s meter not availing Net
Metering or Net Billing arrangement
8.21 Additional Demand Charges for systems not opting for Net Metering/ Billing
MSEDCL’s Submission
8.21.1 Petitioner submitted that the Commission has provided for the Additional Fixed Charges or
Demand Charges and any other charges for consumers of Rooftop Grid Connected RE
Systems not opting for Net Metering or Net Billing Arrangement in the MERC Grid
Interactive Rooftop Renewable Energy Generating Systems Regulations 2019. The relevant
excerpts are given below:
“7.9 Grid Connected Renewable Energy Generating Systems connected behind the
consumer’s meter, and not opting for either Net Metering arrangement or Net
Billing arrangement, shall be allowed only after prior intimation to the respective
Distribution Licensee:
…..Provided further that the Commission may determine additional Fixed Charges
or Demand Charges and any other charges for such Grid Connected systems
excluding non-fossil fuel based co-generation plants, in the retail Tariff Order, if
Distribution Licensee proposes such additional Fixed Charges or Demand
Charges and any other charges for such systems….
Provided also in the case the consumer installs Renewable Energy Generating
Systems behind the consumer’s meter without prior intimation to the respective
Distribution Licensee, then the total additional liabilities in terms of additional
Fixed Charges or Demand Charges ant any other charges for such systems, shall
be levied at twice at the determined rate for such period of default.”
8.21.2 Petitioner submitted that certain consumers connected at EHV/HT level are installing
rooftop RE projects without informing the Distribution Licensee. Such systems take support
of the Grid and the network of the Distribution Licensee and reduces the utilisation of
Transmission/Distribution network and thereby such consumer pay lower charges for such
network setup earlier for it. The unrecovered part of the expenses is then loaded on other
consumers of the Distribution Licensee.
8.21.3 Petitioner proposed Additional Fixed/Demand Charges for Grid connected Renewable
Energy Generating systems connected behind consumer’s meter and not opting for either
Net Metering arrangement or Net Billing arrangement along with the procedure for
MERC Order – Case No. 322 of 2019 Page 536 of 752
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of ARR for FY 2020-21 to FY 2024-25
• Consumer willing to install such Rooftop RE systems shall intimate the Petitioner
with the type and capacity of such system
8.21.4 Petitioner submitted that it has considered the projected ARR for respective year of the
Control Period and bifurcated it into fixed and variable costs. The per unit fixed cost
recovery required is computed using expected average monthly generation. The units
generated in 1 kW rooftop solar plant are computed assuming annual CUF of 19%. Further,
nominal 10% demand/ fixed charges are added to the computed demand/fixed charges so
as to encourage Net Metering or Net Billing arrangement.
8.21.5 The Additional Fixed/ Demand charges computed in Rs./kW/month basis are as under:
Table 8-32: Additional Fixed/Demand Charges for Grid Connected RE Generating Systems
connected behind consumer’s meter
Actual FC Recovery
4.23 3.86 3.83 3.81 3.73
Required (Rs./unit)
Fixed charges to be
recovered 645 589 584 581 568
(Rs./kW/month)
8.21.6 Petitioner submitted that for compensating its common consumers for current level of cross
subsidy, the subsidising consumers shall pay Cross Subsidy Surcharge as proposed for the
respective year of control period.
8.21.7 Petitioner requested the Commission to approve the proposed Additional Fixed/ Demand
Charges along with CSS for Grid Connected Renewable Energy Systems connected behind
the consumer’s meter and not opting for either Net Metering arrangement or Net Billing
arrangement.
8.21.8 Petitioner submitted that the financial impact of the Additional Fixed/ Demand charges is
not considered at present due to uncertainty of usage by consumers but the impact on
revenue of such charges will be considered at the time of final true up.
8.21.9 The Commission opines that registering the grid connected rooftop solar system
installations behind the consumer’s meter not availing net metering or net billing
arrangement and levy of Additional Demand/Fixed Charges for such installations are two
distinct aspects from regulatory governance perspective.
8.21.10Registration of such grid connected rooftop solar system installations behind consumer’s
meter whether or not availing net metering or net billing arrangement is important solely
from the point of view of keeping track of their operational status since such systems are
synchronised with grid distribution system whether or not they export power to the grid. It
is important to ensure operational safety, deployment of adequate protection
systems/islanded mode of operation or anti-islanding features etc. as well as keeping record
of such generation for RPO compliance purpose whether for credit to Utility or credit to be
availed by such consumer if it is an obligated entity. In future, many such systems are
expected to proliferate considering conducive policy/regulatory framework and prosumer
friendly approach adopted by distribution utilities as per prevalent regulatory regime. It is
important to create a registry of such installations for orderly development of the sector.
8.21.11Many objectors/stakeholders have pointed out during public hearing that there are many
such captive installations (conventional generation/co-generation) facilities operating
behind the consumer’s meter, for which no such charges have been proposed. The
Commission would like to highlight that at present, consumers having captive generation
facility synchronised with the grid are required to pay standby demand charges subject to
stipulated conditions. The Commission has already considered the revision in
Standby/Additional Demand Charges for such installations as dealt with under separate
section. Even in such cases, revised Standby/Additional Demand charges are linked to a
percentage of Demand Charges and not linked to shortfall in recovery of Fixed Cost as
proposed by MSEDCL in this case.
8.21.12The Commission observes that Regulations for Grid interactive RTPV systems and the
Statement of Reasons thereof have clearly specified the rationale for levy of such Additional
Demand/Fixed Charges. However, without considering the preparedness, registry and
modalities for implementation, the Commission is deferring the levy of such charges at this
stage for rooftop PV systems behind the consumer’s meter and not availing net metering or
net billing arrangement. f
MSEDCL’s Submission
8.22.1 Petitioner submitted that Ministry of Power has appointed a committee for Tariff
Simplification and another committee for Tariff Rationalisation to suggest measures for
simplification of tariff structure and improve transparency to enhance operational
performance of the distribution utilities. The committees have strongly advocated for
merging of categories and simplify tariff structure. Petitioner further submitted that
simplification of tariff structure is one of the major reasons for the proposal as there have
been addition of slabs and sub-slabs in the tariff categories over the years. Hence, there is a
need to simplify and rationalise the tariff structure.
8.22.2 Petitioner proposed that the consumption based sub-slabs in 0 – 20 kVA for LT Commercial
and LT Public Services may be replaced by a single tariff category of 0-20 kVA. Since,
large number of consumers are shifting to rooftop RE, the high consumption consumers will
automatically shift to lower tariff slabs as a result of merger of these tariff slabs which will
enable simplification of tariff structure.
8.22.3 Thus, Petitioner proposed not to increase substantially, the energy charges for 3 phase
consumers with load less than 20 kW considering the proposed change in kVA based fixed
charges and thus, this will not have impact on small consumer.
8.22.4 As covered under earlier sections, the Commission has extensively dealt with the issue of
tariff category rationalisation and rationalisation of consumption slabs. Further, as ruled
under earlier sections, the tariff redesigning (fixed charge as well as applicability of kVAh
billing) for consumer category below 20 kW would require comprehensive study and impact
analysis on large number of consumers. However, while other aspects of tariff
rationalization can be undertaken over the period, merging of sub-slabs within the sub-
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category would be appropriate in the overall interest of tariff category rationalization and
simplification of the slabs. However, it needs to be ensured that while merging such
consumption slabs, consumers in the lower end consumption slabs do not suffer tariff shock.
The Commission has considered this aspect while merging consumption slab for LT-
Commercial and LT-Public Service.
8.22.5 Thus, the Commission has not accepted MSEDCL’s proposal for revision in consumption
slabs for below 20 kW in respect of LT-Commercial and LT-Public Service.
8.23 Stand-by Charges from Captive Power Producers (CPP) and SEZs
MSEDCL’s Submission
8.23.1 Petitioner submitted that the Commission introduced the additional standby demand charges
in its Order dated 8th September 2004 in Case no.55 and 56 of 2003 (hereby referred to as
“the CPP Order”) wherein, it provided power purchase and other dispensation for fossil fuel
based Captive Power Plants (CPPs). Further, the Commission allowed recovery of
additional demand charges from embedded CPPs through its respective Tariff Orders. The
additional standby demand charges of Rs.20 per kVA is being levied to embedded CPP
holders which were introduced long back and not revised till date.
8.23.2 Petitioner submitted that the CPP Order determining the standby charges for CPP was issued
more than 13 years back considering the then prevailing power supply situation wherein the
circumstances have emerged to be precisely different at present. These charges are still
continued and are on much lower side in comparison to capacity charges payment made by
the Petitioner for serving standby contracted capacity. Petitioner also submitted that such
charges should be revised to fit the present power scenario where the Petitioner gets affected
by over drawl from these CPP holders in present DSM Regulations 2019.
8.23.3 Petitioner submitted that CPP consumers having captive generation facilities who are
synchronised with the Grid require standby facility throughout the year. The standby
arrangement is for the benefit of the consumers so that they receive uninterrupted electricity
supply and the standby charges are the premium (as fixed charges) on such guaranteed
supply which is irrespective of whether any supply is actually drawn under the standby
arrangement or not. Petitioner further submitted that as per the existing dispensation, it can
charge additional demand charges on embedded CPP consumers, only when it is being
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8.23.4 Petitioner submitted that a CPP unit trips due to faults resulting in drawl of power from
MSEDCL which may result in over drawl of power from the Grid by MSEDCL, thus,
affecting the state grid as well as impacting the Petitioner financially in terms of deviation
charges. Moreover, such over drawl may lead to power deficit situation for the existing
consumers of MSEDCL and may result in grid instability. Petitioner further submitted that
it has to plan its power purchase to cater such additional demands and that if penal charges
for exceeding the demand on account of unplanned shutdown of CPP are computed based
on existing provisions then it works out to be minuscule and does not provide adequate
compensation.
8.23.5 Petitioner submitted that the Commission in the last MTR Order already observed that:
“9.35.10 …… the Commission has already determined the standby charges of
Rs.20/kVA for the embedded CPPs. The Commission notes that the same said
charges, which has been worked in the past might require some revision. The same
shall be taken up during next MYT Order for the new Control Period.”
8.23.6 Petitioner further submitted that, additional standby charges for CPPs may be revised in the
following manner considering the present power scenario
Demand Charges on Standby Contracted Capacity
By its very nature, the standby demand has two scenarios as follows:
• Scenario 1: Standby demand is not utilised
25% of applicable
Except planned demand charges on
- -
shutdown standby contracted
capacity
8.23.8 Petitioner submitted that the method stipulated above would reduce the risk borne by CPP
consumers, protect the Petitioner’s consumers from load shedding, compensate the
Petitioner for standby services and is easy to implement and levy.
8.23.9 MSEDCL requested the Commission to make it compulsory for making standby
arrangement for supply of power in case of failure of source generator, as many SEZs and
deemed licensees do not have standby arrangements. In order to ensure 24x7 reliable and
uninterrupted supply to its consumers, Licensees may draw more power from the Grid.
Hence, in order to maintain Grid discipline and to avoid financial impact of penalty of over-
drawl on the Petitioner, it has requested the Commission that SEZ/ Deemed licensees must
have a standby arrangement.
8.23.10The Commission ruled that many of the deemed licensees have their own standby
arrangements where the demand is fulfilled by DG sets installed in different premises within
their licensee area. The Commission further stated that these deemed licensees have not
shown their concerns or requirement for the standby arrangement. The Commission also
ruled that there is no legal mandate on SEZs for standby arrangement.
8.23.11Petitioner submitted that currently there is no mechanism in place to ensure whether there
exists standby arrangement in the form of DG sets within the SEZs/Deemed licensee area
as ruled by the Commission in MTR Order and even if such arrangement exists, whether it
is being used at the time of failure of source generator is not monitored. Petitioner further
submitted that any drawl can be seen only at the time of FBSM as there is no real time
monitoring system with SLDC to ensure that such standby arrangement is being put to use
at the time of unavailability of source generator.
8.23.12Petitioner submitted that it had already submitted the number of instances during which
certain SEZs/ Indian Railways resorted to overdrawl from the Grid, in its review petition on
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8.23.13Petitioner further submitted the exact details of the time blocks during which schedule of
the source generated of M/S Gigaplex (SEZ) was Zero and still there was drawl from the
Grid.
8.23.14Generator schedule and drawl details of M/s Gigaplex is summarised in the following table
(18.30 to 24.00)
(00.00 to 07.00)
8.23.15Petitioner submitted that Indian Railways has also resorted to over drawl from Grid when
the schedule of the source generator of Indian Railways was curtailed as shown in the table
below for FY 2017-18 (upto 25.30.2018)
8.23.16Petitioner submitted that if M/s Gigaplex and M/s Indian Railways have their own standby
arrangement, there is no necessity to draw power from the Grid during the
unavailability/curtailed availability of source generator. Petitioner further submitted that
factual situation is contrary to the ruling of the Commission that the SEZs/Deemed
Licensees have their own standby arrangement.
8.23.17Petitioner reiterated that such situations are not only detrimental to the stability of the Grid
but the undue financial burden of such instances is also getting passed onto its consumers
for no fault on their part and therefore, SEZs /Deemed Licensee and Indian Railways must
have standby arrangement
8.23.18Petitioner further submitted that it has submitted a letter on 8th February 2019 highlighting
the issues pertaining to SEZ. The said letter is attached as Annexure 9 to the petition
8.23.20In the MYT Orders for the three Mumbai Distribution Licensees, viz. Tata Power Co. Ltd.
(Case No.326 of 2019), Adani Electricity Mumbai Ltd. (Case No.325 of 2019) and BEST
(Case No.324 of 2018), the Commission has decided their Stand-by Demand contribution
based on average Coincident Peak Demand (CPD) and Non-coincident Peak Demand
(NCPD) used for sharing the Total Transmission System Charges.
8.23.21Further, as elaborated in the previous MTR Order in Case No. 195 of 2017, with reference
to the Commission rulings in Case No. 53 of 2017 in the matter of review of the Stand-by
Arrangement with MSEDCL, for the Mumbai Distribution area, and related issues, the
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Commission had decided the share of Stand-by charges would now be shared amongst the
Indian Railways (Mumbai Area) and rest other three Mumbai Distribution Licensees.
8.23.22In view of above and based on the revised average CPD and NCPD (Base TCR) as approved
in the latest InSTS Tariff Order dated 12 September, 2018 in Case No. 265 of 2018, the
Commission has determined the share of these three Licensees and Indian Railways
(Mumbai Area) in the Stand-by charges for FY 2020-21 to FY 2024-25.
Table 8-33: Standby Charges for FY 2020-21 to FY 2024-25, as approved by the
Commission
8.23.23The Commission observes that the present dispensation for Standby charges for CPP was
first introduced under its CPP Order dated 8th September 2004 in Case no.55 and 56 of
2003.The power scenario and energy planning by both, Utility and consumer has undergone
significant change since then. In the last MTR Order, the Commission has observed that
standby charges for CPP as determined may need revision and can be considered at the time
of next MYT filing. Relevant extract of the MTR Order is as under:
“9.35.10 …… the Commission has already determined the standby charges of
Rs.20/kVA for the embedded CPPs. The Commission notes that the same said
charges, which has been worked in the past might require some revision. The same
shall be taken up during next MYT Order for the new Control Period.”
8.23.24In this context, as part of data gaps, the Commission sought the instances of over drawls by
CPP in the State, which has affected the State Grid’s and MSEDCL’s consequent financial
implications due to Deviation Charges along with the instance of tripping in a year by CPPs,
to which MSEDCL submitted that, there are 35 nos. of Embedded CPP’s (Thermal). During
FY 2017-18 there are 63 instances & during FY 2018-19 there are 41 instances of over
drawls by embedded CPP’s. MSEDCL further submitted that due to metering arrangements
(ABT and ToD Meters), it would be difficult to provide financial implications for such over
drawls. MSEDCL also provided the list of consumers overdrawing the beyond their allotted
Contract Demand, the details of the same is provided in the Table below:
Particulars FY 2017-18 FY 2018-19
Total No. of Consumers 63 41
Total Contract Demand (kVA) 188,786 109,931
Total Max. Demand Recorded (kVA) 305,966 254,628
8.23.25Further, the Commission also sought MSEDCL’s proposal of penal charges as proposed to
be applied on CPP when it exceeds its demand during unplanned shutdowns, where
MSEDCL submitted that, the same is covered in its submission above. However, while
analysing the details of instances the Commission is of the view that, the details submitted
by MSEDCL is not evident enough to point that, the such Overdrawal instances are due to
embedded CPPs, since only the consumers numbers for respective instances were provided.
In addition, MSEDCL has itself submitted that, due to lack of metering infrastructure, the
financial implications due to such Overdrawal would be difficult to estimate at this stage.
8.23.26Nonetheless, the Commission also acknowledges that with introduction of DSM regime as
per MERC DSM Regulations, 2019, the licensees/ generators/ TSUs would be subject to
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stringent scheduling and despatch regime with consequent implications of the Deviation
charges/Additional Deviation charges for deviation from the schedule, if any. The standby
support availed by such CPPs (in planned or un-planned manner) has direct bearing on the
scheduling regime, power purchase planning and management of imbalances/deviations by
the Utility. The Commission observes that the arrangement for Standby power capacity is
optional at the choice of CPP. However, the pricing for usage of standby capacity during
planned and un-planned shutdown should not be so low as to cause undue burden on the
Utility for its management/arrangement of capacity to cater to standby requirement and at
the same time it should not be priced so high so that CPP users hesitate to opt for such
standby facility from Utility.
8.23.27Under the circumstances, upon careful consideration of all facts, the Commission opines
that the framework for levy of Standby charges as proposed by MSEDCL is fair and
Commission has decided to adopted it with following modifications, as it caters to all cases
of supply availed by CPP under Standby arrangement and encourages discipline as regards
power planning, load generation balancing and availing standby support while ensuring
minimal cost burden for Utility and CPP as well.
8.23.28Accordingly, the Commission approves the following arrangement for levy of Standby
Charges and other conditions/charges to be applicable for availing power supply under
standby arrangement by CPP Users. Demand Charges on standby contracted capacity by
CPP consumer shall apply in following manner:
• 25% of the Applicable Demand Charges for months when standby capacity is not
utilized
• Demand Charges at the rate of 100% of Applicable Demand Charges for months
when standby capacity is not used under planned or un-planned shutdown of CPP
• In case of CPP Users, who do not opt for Standby power arrangement, in such cases
of CPP users for their planned or un-planned outage, Additional Demand Charges
at the rate of 200% of Applicable Demand Charges (on monthly basis) shall be
levied on the quantum exceeding their contract demand only if recorded demand
exceeds contract demand.
8.24.1 In case of SEZs, the Commission is of the view that, as highlighted by MSEDCL many of
the Deemed Distribution Licensees have their own Stand-by arrangements, where the
demand is fulfilled by DG Sets installed in different premises of their Licensee area. Thus,
as such these Deemed Licensees have not shown their concerns or requirement for the
Stand-by arrangement.
8.24.2 Further, some of the Deemed Licensee have acknowledged the drawl from the grid, when
generators have failed to supply, in such cases SLDC should have directed the Deemed
Licensee to curtail its Load. Such exceptional circumstances cannot be the ground for
mandating SEZs to pay Stand-by Charges to MSEDCL, when it already has 100% standby
DG Set as mandated under the SEZ Act.
8.24.3 Further, the Commission observes that SEZs/Deemed Distribution Licensees, being TSUs
are also participants in the Deviation Pool account and be subjected to scheduling/despatch
regime and rules for Deviation settlement mechanisms and would attract deviation
charges/additional deviation charges as per MERC DSM Regulations, 2019 and procedures
formulated therein. Further, Additional Deviation charges for exceeding their volume limits
would also be applicable under DSM regime.
8.24.4 Further, in such scenario the requirement of additional supply may be raised before
MSEDCL, since, the Licensee can sell the power as per the Short-Term Rates inclusive of
other applicable charges to the Licensee. In addition, SEZ being a pool participant, the over
drawl instance will be subjected to DSM charges for deviations.
8.24.5 Thus, in view of above facts, the Commission rules that levy of Stand-by Charges will not
be applicable to the SEZ and Deemed Licensee.
MSEDCL’s Submissions
8.25.1 Petitioner submitted that the Commission in its MTR Order dated 12th September 2018 has
observed that the revision in ToD slabs and rates thereof would depend upon factors such
as load curve, demand side measures, overall system demand management measures in
vogue, etc. The Commission further ruled that as this issue must be seen in totality across
all Licensees, it would take a view on proposals to modify the ToD time slots and /or ToD
slot wise tariffs in the next control period
8.25.2 In existing TOD tariff concept, rebate or penalty is same in all month irrespective of load
pattern, surplus & shortfall in availability. There is no consideration of impact of RE
generation which will be one of important change in generation mix. Moreover, due to
various Govt. of India policies to promote RE generation and as per the RPO Targets set for
Utilities by the Commission, tremendous rise in RE generation is expected. The major rise
is in solar generation which has typical shape of inverted hyperbola. There is no or very less
generation during specific time period of a day; particularly during 06:00 to 09:00 and
during 15:00 to 19:00 Hrs. Considering the demand pattern and expected Solar Generation,
Petitioner has proposed revision in ToD tariff /rates
8.25.3 Petitioner submitted that the existing ToD slabs and Tariffs may be followed with the
revision in ToD tariffs as shown in the table below. However, with the increasing share of
renewable generations over the last few years, it is necessary to revise ToD slabs so as to
change the demand pattern of consumers to enable the utilities to meet their peak demand
effectively. Petitioner further submitted that it shall propose revision in ToD slabs and tariffs
based on the existing and upcoming renewable capacity additions and the demand-supply
scenario at the time of filing of the next MTR petition.
Consumption Slab Existing ToD charge Proposed ToD charge
(kWh) (Rs./kWh) (Rs./kWh)
8.25.4 Petitioner requested the Commission to approve the revision in ToD charges as proposed
Commission’s Analysis and Rulings
8.25.5 MSEDCL has requested the Commission to revise ToD slots and charges with the claim of
upcoming increase in RE installed capacity and hence, higher amount of penetration in grid
from RE plants.
8.25.6 The Commission had sought Hourly, Seasonal & Average Load Curve for the past three
years, for establishing the basis of proposed changes in the ToD Rates along with the
revenue impact of such proposed revision in the ToD Charges on MSEDCL as part of Data
gaps, to which MSEDCL has submitted the required data, while the revenue impact
estimated for the ensuing years is ~896 Crore, but no detailed rationale or analysis for
revision is provided by MSEDCL. While analysing the data sought from MSEDCL, the
Commission has also analysed the hourly trend of Load along with the existing ToD Rates
as well as the Short Term Prices discovered at Power Exchange..
8.25.7 In the past the Commission has followed centralized MoD approach and standardised ToD
timeslots and rates. The Commission upon analysing the same observed that, the existing
ToD structure matches with the rates prevalent in the Power Exchange, i.e., ToD rate is high
when Power Exchange power is costly and ToD rate is low when Power Exchange power
is cheaper. From 1 April 2020, the State is shifting to decentralized MoD under the DSM
framework, and each DISCOM must plan its power procurement as per its load curve.
Hence, the ToD structure can be different for each DISCOM. If proposed changes in ToD
rates are accepted, it will result into consumer shift from DISCOM to RE plants. Penalising
consumers in such a manner will result into loss of consumers for DISCOMs.
8.25.8 In addition, RPO Regulations for the next Control Period envisages substantial increase in
Solar power, which will be helping the load curve as it shall be contributing to meet the
daytime peak load requirement. Such RE projects would be commissioned in the next
couple of years. Hence, at the time of MTR, it would be appropriate to revisit and revise, if
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necessary, the ToD timeslots and rates as per DISCOM’s power procurement planning. The
Commission may also consider having seasonal ToD rate in order to assist the DISCOMs
to absorb seasonal variation in RE generation which as per RPO Regulations, 2019 would
be 25% in FY 2024-25
8.25.9 Thus, in view of above, the Commission has decided to continue with the existing structure
of ToD slots and applicable charges and directs MSEDCL to submit a detailed proposal at
the time of MTR.
MSEDCL’s Submission
8.26.1 MSEDCL submitted that the Central Electricity Authority on 6th February 2019 had notified
amendment to the CEA (Technical Standards for Connectivity to the Grid) Regulations
2007. The amendment states that the Distribution Licensee and Bulk consumers are required
to provide adequate reactive compensation to compensate reactive power requirement in the
system and mandates for installation of power quality meter and sharing the recorded data
thereof. The relevant extracts of the Regulations are reproduced below:
“(2) (i) The Distribution Licensee and bulk consumer shall provide adequate reactive
compensation to compensate reactive power requirement in their system so that they
do not depend upon the grid for reactive power support.
(ii) The power factor for distribution system and bulk consumer shall be within ± 0.95;
(3) Voltage and Current Harmonics –
(i) The limits of voltage harmonics by the distribution licensee in its electricity system,
the limits of injection of current harmonics by bulk consumers, point of harmonics
measurement i.e. point of common coupling , method of harmonic measurement and
other related matters, shall be in accordance with the IEEE 519-2014 standards, as
amended from time to time;
…..
(iv) The bulk consumer shall install power quality meter and share the recorded data
thereof with the Distribution Licensee with such periodicity as may be specified by the
appropriate Electricity Regulatory Commission.”
8.26.2 MSEDCL submitted that the Regulation 2.1 (i) of the MERC (Electricity Supply code and
other Conditions of Supply) Regulations, 2005 defines “Harmonics” as under:
“Regulation 2.1 (l) “Harmonics” means a component of a periodic wave having
frequency that is an integral multiple of the fundamental power line frequency of 50
Hz causing distortion to pure sinusoidal waveform of voltage or current, and as
governed by IEEE STD 519-1992, namely “IEEE Recommended Practices and
Requirements for Harmonic Control in Electrical Power Systems” and corresponding
standard as may be specified in accordance with clause (c) of subsection (2) of section
185 of the Act.”
8.26.3 MSEDCL states that from the definition, it is understood that the presence of harmonics in
electrical systems means that the current and/or voltage are distorted and deviated from the
sinusoidal waveform.
8.26.4 MSEDCL further submitted that the Regulation 12.1 of MERC Supply Code provides that
the certain categories of HT consumers and LT consumers (Industrial and Commercial) are
required to control the harmonics generated in their system on account of their load. The
Regulation is reproduced below:
“12.1 It shall be obligatory for the consumer……..
Provided that it shall be obligatory for the HT consumer and the LT consumer
(Industrial and Commercial only) to control harmonics of his load at levels prescribed
by the IEE STD 519-1992 and in accordance with the relevant Orders of the
Commission.”
8.26.5 MSEDCL further submitted that Regulation 12.2 MERC Supply Code Regulations 2005
provides for the minimum time period given to the consumer to make necessary changes in
their system so as to control harmonics (or) improve the system’s power factor. Further, the
said Regulations also set provisions for penalizing the neglecter for failing to do so. This
may attract penalty for not controlling harmonics within the prescribed limit. The
Regulation is reproduced below:
“12.2 The Distribution Licensee may require the consumer within a reasonable time
period which shall not be less than three months, to take such effective measures so
as to raise the average power factor or control harmonics of his installation to a value
not less than such norm, in accordance with Regulation 12.1 above
Provided that the Distribution Licensee may charge penalty or provide incentives for
low/high power factor and for harmonics, in accordance with relevant orders of the
Commission.”
8.26.6 MSEDCL submitted that its consumers use various non-linear loads in industrial and
commercial establishments which demand non-sinusoidal currents which are reach in
harmonics with higher frequencies of 150 Hz, 250 Hz, etc. Such currents cause overheating
of transformers, cables, switchgears, thus causing insulation deterioration and nuisance
tripping in control circuits. Thus, harmonics are necessary to control as excessive current
harmonics result in voltage harmonics and hence, poor power quality.
8.26.7 MSEDCL mentioned the fact that industrial systems have been moving towards non-linear
load equipment which result in higher harmonics in the system leading to increased iron
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and copper losses in upstream electrical equipment in distribution systems which do not get
metered to the consumer. MSEDCL also mentioned that the increase THD levels (Total
Harmonic Distortion) will have adverse effects on the equipment of the utility which affects
the operational efficiency of the utility as well as consumers.
8.26.8 MSEDCL submitted some of the effects of harmonics on various components as mentioned
below:
• Power Cables and Capacitor: Voltage stress induces higher corona losses
resulting in dielectric failure
• Meters: Non-linear voltages and current induce errors into the measurement circuit
resulting in false readings
• Switch gear and relay: The out-of-balance current causes spurious/false operations
and might operate false alarms and trips.
8.26.9 MSEDCL had filed a Petition before the Commission for amendment in SOP Regulations
related to Harmonics limits and prayed for effective implementation of Regulation 12.2 of
the Supply Code Regulations 2005 (Case No. 34 of 2011).
8.26.10The Commission vide its Order dated 24.12.2012 opined that introduction of penalty for
injection of the Harmonics at this stage will be premature. Instead of introduction of penalty,
Petitioner needs to analyse existing level of Harmonics in the system and determine causes
and remedial measures for limiting the same. The Commission further observed that
Petitioner needs to arrange a program for creating awareness amongst the consumers about
effects of Harmonics on the power equipment.
8.26.12The Commission vide its Order dated 17th August 2015 rejected the claim of Petitioner
citing pendency of response to directives in Case No.34 of 2011
8.26.13MSEDCL, as per the directives of the Commission, carried out a study of harmonics
measurement at the substation end in Load ON and OFF conditions as well as at various HT
consumers.
8.26.14MSEDCL submitted that the measurement of Harmonics was carried out by its field
engineers using Electronic Reference Standard Meter (Make: Zera, Class: 0.2S) available
with MSEDCL and the THD is measured at consumer premises as well as at substation end.
8.26.15MSEDCL mentioned that, out of 21810 HT consumers for whom harmonics were
measured, 9905 consumers have shown abnormalities of about 45% which is very high.
8.26.16MSEDCL submitted that, in order to further confirm the abnormalities, it decided to appoint
an expert third party agency (M/s. SAS PowerTech P. Ltd., Pune) to undertake measurement
of harmonics and analyse the issues involved in respect of sample 100 HT consumers spread
all over the state including 25 consumers from each region strictly as per the requirements
of IEEE 519 : 1992. This exercise was carried out with the assistance of the third-party
expert agency in the field of harmonics measurement and analysis in order to cross verify
and validate the observations made by the Petitioner’s field engineers.
8.26.17MSEDCL further mentioned that M/s. SAS PowerTech P. Ltd., Pune completed the work
of measurement of harmonics at selected 100 HT consumers premises in May 2018 and
submitted the report of detailed analysis in June 2018. These measurements and recordings
were carried out for 24 hours at each consumer premises at HT PCC between the MSEDCL
and consumer electrical system.
8.26.18MSEDCL mentioned that, out of 100 HT consumers, 31 consumers were exceeding the
permissible limits of TDD compliance, 10 consumers had their TDD at border level while
4 consumers were found exceeding voltage harmonic compliance.
Regulatory Provisions for Harmonics
8.26.19MSEDCL submitted that IEEE Standard namely “IEEE 519-1992 – IEEE Recommended
Practices and Requirements for Harmonic Control in Electrical Power Systems” provides
for the requirement for harmonics control.
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8.26.20MSEDCL submitted that the CEA on 6th February 2019 has notified amendment to CEA
(Technical Standards for Connectivity to the Grid) Regulations 2007 as per which, the
Distribution Licensees and the Bulk consumers are required to provide adequate reactive
compensation to compensate reactive power requirement in their system. The amendment
mandates the installation of power quality meter and sharing the recorded data thereof.
8.26.21MSEDCL further submitted that Regulation 12.1 of MERC (Electricity Supply Code &
Other conditions of (Supply) Regulation 2005 provides that it shall be obligatory for HT
consumers to control harmonics of his loads at level prescribed by IEEE Standard 519-1992
8.26.22MSEDCL mentioned the current distortion limits as per the IEEE 519-2014 for general
distribution system (120V to 69000V) as below:
Maximum Harmonic Current Distortion in % of IL
8.26.23MSEDCL mentioned the current distortion limits as per the IEEE 519-2014 for general
distribution system (69 kV to 161 kV) as below:
Maximum Harmonic Current Distortion in % of IL
8.26.24MSEDCL mentioned the current distortion limits as per the IEEE 519-2014 for general
distribution system (above 161 kV) as below:
Maximum Harmonic Current Distortion in % of IL
Even harmonics are limited to 25% of the odd harmonic limits. TDD refers to the Total
Demand Distortion and is based on the average maximum demand current at the
fundamental frequency taken at the PCC
*All power generation equipment is limited to these values of current distortion
regardless of Isc/IL
Isc = Maximum short circuit current at the PCC
IL = Maximum demand load current (fundamental) at the PCC
h = Harmonic Number
8.26.25MSEDCL submitted that IEEE 519-2014 has introduced statistical evaluation (very short
and short time harmonic measurements), having same limits as mentioned in IEEE 519-
1992.
8.26.26MSEDCL further submitted that Tamil Nadu Electricity Regulatory Commission (TNERC)
through its order dated 30th Match 2012 has permitted the utility to levy harmonic
compensation of 15% of respective tariff for High tension consumers for non-compliance
of Harmonics limit.
8.26.27In view of the above, MSEDCL has requested the Commission to propose the following:
8.26.29Carry out harmonic survey along with quarterly/annual testing. If any consumer is found
with harmonics level beyond limits specified in IEEE STD 519-2014, then the Petitioner
will serve a notice indicating test results an intimation to take corrective action for
harmonics suppression within 3 months from the date of service of the notice.
8.26.30Petitioner stated that consumers are required to file report of compliance accompanied with
test certificates of harmonic filters, invoices and commissioning report. For such consumers
who provide compliance to the notice, no penalty shall be levied, but it is expected that they
will maintain harmonic filters in working condition
8.26.31Consumers who do not adhere to notice stipulations will be charged additional energy
charges for consumption beyond 6 months till rectification of defect.
8.26.32If the consumer has not complied with the stipulations of the notice or has maintained
harmonic filters in working conditions, then MSEDCL will apply harmonics penalty for
past consumption i.e. from date of serving of notice and for future consumption till
rectification of defect.
8.26.34MSEDCL further submitted that the HT Industrial and Commercial consumers shall install
power quality meters within six months period and share the recorded data with the
Petitioner on quarterly basis.
8.26.35The Commission notes that harmonics in Industries is largely generated from the use of
Variable Frequency Drives (VFDs) for large motors with fluctuating load conditions. This
being one of the largest sources may not be present in all plants. Further, the Commission
opines that the generalization of the fact that all HT and LT-commercial consumers inject
Harmonics into the utility’s network denies the benefit of investments made by some plants
in installing filters to control the harmonic level.
8.26.36The Commission noted the suggestions and objections from various stakeholders on the
issue of Harmonic Penalty. Although most of the stakeholders have opposed imposing
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penalty, all desired to get quality power supply from MSEDCL. The Commission notes that
Consumers and Distribution Licensee are jointly responsible for Harmonics. Distribution
Licensees are responsible for Voltage Harmonics whereas Consumers are responsible for
Current Harmonics. However, to fix accountability of Harmonics, it is important to have
power quality meter which can measure and record continuous data of power harmonics.
Such meter should also be capable of differentiating and recording harmonics being injected
from both direction i.e. for consumer, injection from Distribution System and injection into
Distribution System. Without having such data based on continuous monitoring and its
analysis, the Commission would not be able to impose any incentive or penalty for
Harmonics.
8.26.37In this context, the Commission would like to highlight the provisions of Regulation 5 (3)
of CEA (Technical Standards for connectivity to Grid) (Amendment) Regulations, 2019
notified on 6th February 2019 which clearly specifies the conditions for Voltage/Current
Harnonics, role and responsibility of entities and timelines for corrective actions in case of
shortfall in performance on harmonics than that stipulated as per standards. Relevant extract
of the said CEA Regulations is as under:
“(3) Voltage and Current Harmonics. - (i) The limits of voltage harmonics by the
distribution licensee in its electricity system, the limits of injection of current
harmonics by bulk consumers, point of harmonic measurement, i.e., point of
common coupling, method of harmonic measurement and other related matters,
shall be in accordance with the IEEE 519-2014 standards, as amended from time to
time;
(ii) Measuring and metering of harmonics shall be a continuous process with meters
complying with provisions of IEC 61000-4-30 Class A.
(iii) The data measured and metered as mentioned in sub-paragraph (ii) with regard
to the harmonics, shall be available with distribution licensee and it shall also be
shared with the consumer periodically.
(iv) The bulk consumer shall install power quality meter and share the recorded
data thereof with the distribution licensee with such periodicity as may be specified
by the appropriate Electricity Regulatory Commission:
Provided that the existing bulk consumer shall comply with this provision within
twelve months from the date of commencement of the Central Electricity Authority
(Technical Standards for Connectivity to the Grid) (Amendment) Regulations,
2018.”
8.26.38Having said that the Commission is cognizant of issue of power quality. Hence, in order to
ensure that requisite data is available before next tariff determination process, the
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Commission has laid down time frame for installation of power quality meter as per
mandates of CEA Regulations. Accordingly, all Bulk Consumers with Contract Demand
above 20 MVA shall install power quality meter by March 2021 (and above 10 MVA by
March 2022) and share monthly data with Distribution Licensee. Also, Distribution
Licensee needs to install power quality meter at their selected substations and share the data
from these meter on its website.
8.26.39The Commission opines that introduction of penalty for HT consumers for injection of the
Harmonics can be undertaken upon analysis of data to be made available through power
quality meters. Hence, the Commission has not introduced any Harmonics penalty at this
stage. The Commission further observes that MSEDCL needs to arrange a program for
creating awareness amongst the consumers about effects of Harmonics on the power
equipment.
8.27 Expenses for Go Green Initiative (E-Copy of the Bill) and SMS Service
MSEDCL’s Submission
8.27.1 MSEDCL submitted that it may decide and continue with SMS services and may increase
rebate to Rs. 10/- per bill under Go-Green initiative which could be linked to a percentage
of bill amount or Rs 10/- per bill whichever is higher, as opined by the Commission in its
Order dated 19th March 2019 in Case No.1 of 2019. This expenditure pass through would
either be treated as an expenditure under O&M and more specifically under A&G or would
be considered as a pass through subject to submission of cost benefit analysis justifying the
expense incurred, during its upcoming tariff Petition.
8.27.2 Petitioner proposed to provide a rebate of Rs.10 on every electricity bill to the consumers
who opt for an electronic copy of the bill instead of the hard copy under its “Go Green”
initiative, in order to encourage consumers to participate in Digital Program. Go Green
initiative is a voluntary initiative wherein consumers are free to opt for an electronic copy
of the bill instead of the hard copy as per their willingness
8.27.3 Petitioner submitted that earlier it was giving a discount of Rs.3 on every electricity bill
since 2016, but has not decided to offer a discount of Rs.10 per electricity bill to consumers
opting for electronic bill in order to encourage more participation in Go Green initiative
which was implemented w.e.f. 1st December 2018 for LT consumers.
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8.27.4 Petitioner mentioned that, currently, 59,040 consumers have opted for Go Green initiative
and it has registered email addresses of 14 lakh consumers while more than 50 lakh
consumers are paying online. Petitioner further submitted that it expects more and more
consumers to opt for electronic copy of the bill. Petitioner, thus, requested the Commission
to allow expenditure for Go Green Initiative as revenue expenditure over and above the
normative O&M expenses.
Expenses for SMS Service
8.27.5 Petitioner submitted that the Commission in its MTR Order in Case No.195 of 2017 noted
that serving of notices to the consumers through digital medium such as WhatsApp
message, email, SMS etc. will not only be environment friendly and save administrative
cost but also would free the human resources for other consumer service related works.
Hence, the Commission allowed the Petitioner to issue notices under Section 56 of the
Electricity Act, 2003 through digital mode such as WhatsApp message, email, SMS etc.
8.27.6 Petitioner submitted that new SMS services are introduced for employees through
Employee portal, vendors through vendor payment system and for Solar AG Consumers.
Various SMS campaigns are also executed for informing consumers about MSEDCL
schemes and major breakdowns during emergencies and natural calamities etc. Recently
added Meter Reading Intimation SMS makes consumer aware that meter reader is going to
visit his/her premises for capturing reading Meter Reading in particular slots.
8.27.7 Petitioner submitted that the SMS service will help not only consumer but MSEDCL also
in information disseminating in a matter of seconds to large section of consumers at one go.
Petitioner further submitted that, the Delhi Electricity Regulatory Commission (DERC) in
its Order in the matter of Petition for approval of Annual Revenue Requirement (ARR) of
Tata Power Delhi Distribution Ltd. for the FY 2018-19, Revised ARR for FY 2017-18, True
up for FY 2016-17 has approved expenses of SMS services separately in ARR under other
expenses. Petitioner requested the Commission to allow the expenditure for SMS Services
as revenue expenditure over and above the normative O&M Expenses.
Commission’s Analysis & Rulings
8.27.8 Commission has noted the submissions made by MSEDCL for Go Green Initiatives with E-
Billing and SMS service taken by DISCOM and its benefits. Commission appreciates the
steps taken by MSEDCL towards Go Green Initiatives with the way of saving paper used
for electricity bills and other stationary materials. However, the detailed rationale for the
same and way of funding such schemes is already discussed under Opex Scheme by the
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Commission in this MYT Order.As far as proposal for rebate to consumers for opting for
Go Green initiative is concerned, the same is allowed and costs pertaining to such rebate
shall be allowed as pass through in ARR in line with Regulation 84.1 of MYT Regulations
2019. However, MSEDCL should maintain separate account of such rebates and details of
consumers opting for such Go-Green initiative. Further, MSEDCL should also arrange
awareness campaigns through mailers/bills, engage in outreach activities to promote this
initiative and also through its customer care centres.
MSEDCL’s Submission
8.28.1 Petitioner submitted share of the electricity consumption by the agricultural category
consumers is ~30 % of the total electricity consumption. The electricity tariff of the
agriculture category consumers is being determined to be much less than the Average Cost
of Supply effectively increasing the tariff of other category consumers by way of cross
subsidy. At the same time, revenue realised from the agriculture consumers is also less
owing to various reasons such as poor capacity to pay, uncertain agricultural produce due
to unpredictable rainfall etc. This AG cross subsidy is getting passed on to other subsidizing
consumers of the Petitioner and increasing their tariff further.
8.28.2 Petitioner submitted that, the higher tariffs of the cross-subsidising consumers (Industrial,
Commercial, high end residential etc.) is impacting its sales and revenue thereby requiring
tariff hike and thus entering into a vicious circle. Hence there is a necessity to maintain a
balance in tariff of the subsidised AG consumers and the high-end subsidising consumers.
8.28.3 Petitioner submitted that the consumer base of Mumbai licensees (Tata, Adani, BEST) as
well as other SEZs comprises mostly of high-end consumers (Industrial, Commercial, high
end Residential etc.) that have higher capacity to pay in comparison to the Agricultural
category consumers. For Mumbai Licensees and SEZs, as there are no AG consumers, there
is no impact on the tariff of these consumers because of cross subsidy for agricultural
consumers. Thus, the consumers of Mumbai Licensees and SEZs are protected from
payment of the cross subsidy for AG consumers. Petitioner also submitted that since all AG
consumers are in its License Area, it has created imbalance in revenue recovery.
8.28.4 Stating a fact that the benefits of the agricultural produce from the agricultural consumers
of the Petitioner are being enjoyed by all the consumers of Maharashtra including Mumbai
Licensees and SEZs, Petitioner proposed to share equally, the impact of such cross subsidy,
by all the consumers of the state of Maharashtra including those in the area of Mumbai
Licensees and SEZs as it will reduce differentiation among similar category consumers.
Petitioner, thus, requested the Commission to take note of the same and address the issue in
larger benefit of similarly placed electricity consumers in the state.
8.28.5 Petitioner further submitted that proposed amendment in the EA 2003 provides for
separation of carriage and contents. As a result, multiple supply Licensees will be
introduced in State. Petitioner also submitted that, being a Supply Licensee, the impact of
cross subsidy of all the AG consumers in its area will be on the Petitioner itself. Hence, the
cross-subsidy impact needs to be distributed amongst all the Supply Licensees in
Maharashtra which is in line with the proposed amendment.
8.28.6 Petitioner has estimated the overall cross subsidy impact on Mumbai Utilities is around Rs.
1,896 Crore and requested the Commission to use its inherent powers to decide the matters
in the interest of consumers as well as utilities.
8.28.7 The Commission has noted the submissions and is of the view that, the same is not legally
tenable as per the Electricity Act, 2003, as cross-subsidising inter-se amongst licensees is
not envisaged under the Act as each Utilities ARR and Tariff determination is to be
undertaken based on its consumer mix/sales mix/power purchase mix, network topography
in accordance with the principles specified under MYT Regulations.
8.28.8 The Act empowers the Appropriate Government to extend subsidy to Licensee in case any
consumer category /class of consumers needs to be provided subsidy against the tariff
determined by the Commission and State Government can extend the same in pursuance of
Section 65 of the Electricity Act 2003. Further the Government is empowered to determine
the Electricity Duty and Tax on Sale of Electricity as per the relevant Acts. Thus, the
Commission has not accepted the claim of MSEDCL of sharing the Cross-subsidy impact
with Mumbai Utilities.
MSEDCL’s Submission
8.29.1 Petitioner submitted that the Commission has provided the ratio of network and supply cost
segregation in MYT Regulations 2019 and the Petitioner has considered the same for
segregation of average revenue requirement for the control period and arrived at the wires
business and retail supply business cost. Following table provides the summary of network
cost of the Petitioner for the control period
Table 8-34: Network cost of MSEDCL for FY 2020-21 to FY 2024-25
Sr. FY FY FY FY FY
Particulars
No. 2020-21 2021-22 2022-23 2023-24 2024-25
8 Opex schemes 87 87 87 87 87
Contribution to contingency
9 143 159 171 175 180
reserves
10 Income Tax - - - - -
8.29.2 Petitioner submitted that the Regulation 73.2 of MERC (Multi Year Tariff) Regulations
2019 provides for computation of wheeling charges separately for LT voltage, HT voltage
and EHT voltage levels. The relevant extract of such regulations are given below:
“73.2 The Wheeling Charges of the Distribution Licensee shall be determined by
the Commission on the basis of a Petition for determination of Tariff filed by the
Distribution Licensee in accordance with Part B of these Regulations:
8.29.3 Petitioner submitted that for the control period from FY 2020-21 to FY 2024-25, it has
proposed Wheeling Charges for three levels only, EHV (66kV and above), HT (combined
wheeling charges for 33, 22 & 11 kV) and LT level.
8.29.4 Petitioner submitted that it does not maintain audited accounts for voltage wise assets and
thus it does not have segregation between GFA for HT and LT Levels. Hence, Petitioner,
for the purpose of projection, has considered GFA segregated into HT and LT as considered
by the Commission in the Mid Term Review Order dated 12th September 2018. Petitioner
further submitted that in order to arrive at the proportion of GFA for HT Level, it has added
the GFA proportion for 33 kV, 22 kV and 11 kV voltage levels and the same is shown in
the table below.
8.29.5 Petitioner has applied ratio of voltage-wise GFA shown in the above table to arrive at GFA
of HT (excluding EHV level) and LT levels asset which has been approved by the
Commission in its Order dated 12th September 2018
8.29.6 The network cost is apportioned among voltage level in the ratio of GFA as computed
above:
Table 8-36: Network cost apportioned for the control period (Rs. Crore)
Particulars FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25
8.29.7 Petitioner submitted that it has considered the voltage wise consumption (in kVAh also) as
projected in Form 1.2 for the respective years of the control period for determining the
wheeling charges. The projected consumption at different voltage levels is shown below:
Table 8-37: Voltage wise consumption for the control period, in MUs
Particulars FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25
8.29.8 Petitioner submitted that, to arrive at the cost of wheeling at various voltage levels, the total
wire network cost (as computed above) has been apportioned to the various levels (i.e. HT
(excluding EHV) and LT) in the ratio of sales at respective voltage levels. The wire costs at
higher voltage levels have been further apportioned to lower voltage levels, since the HT
system is also being used for supply to the LT consumers
8.29.9 Using the same methodology, the Petitioner has computed the wheeling cost for the entire
control period
8.29.10Petitioner has submitted that it has calculated the share of each voltage category in the non-
incident peak demand using % sales for each category. The wheeling charges have been
derived by dividing the wheeling cost of each voltage category (as computed above) by the
non-coincidental peak demand for that category and dividing it by 12 months
8.29.11Petitioner submitted that the wheeling charges have been calculated by dividing the
wheeling charges for each category by the load factor (assumed to be 66%) and 720 hours
(24x30)
8.29.12Petitioner submitted that using the same methodology, the Petitioner has computed the
wheeling cost for the entire control period. The proposed wheeling charges for the control
period are given below:
Table 8-40: Proposed Wheeling Charges for the control period, in Rs./unit
FY 2020- FY 2021- FY 2022- FY 2023- FY 2024-
Particulars Units
21 22 23 24 25
8.29.13Petitioner proposed to continue the following wheeling losses which are already approved
in previous Tariff Orders for the purpose of commercial settlement
33 kV 6.00%
22 kV 7.50%
11 kV 9.00%
LT 12.00%
8.29.15The Commission in the previous MTR Order estimated the voltage wise Wheeling Charges
for 33 kV, 22 kV, 11 kV and LT level consumers. Whereas in the present MYT Petition, in
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line with the Regulation 73.2 of the MYT Regulations, 2019, the Wheeling Charges shall
now be determined for LT, HT and EHV voltage levels only.
8.29.16The Commission in its every Tariff Order has directed MSEDCL to provide the Voltage
wise GFA details, but the same have not been complied till date. Thus, in absence of
Voltage-wise Network Cost, the Commission has considered estimate of the voltage wise
GFA ratio considering assumptions on various parameters that influences the determination
of GFA ratio such as HT/LT circuit km, Substation Capacity (HT/LT), Number of DTCs/DT
capacity, Voltage-wise sales at HT/LT, Energy Units handled at HT/LT etc. and accordingly
derived the ratio for allocation of wheeling cost between HT and LT, which is summarised
as under:
8.29.17 Based on the GFA Ratio, the Commission has worked out the Voltage-wise energy sales,
excluding EHV Sales, of HT and LT Levels for FY 2020-21 to FY 2024-25.
Table 8-43: Voltage-wise Wheeling Cost Allocation for computation of Wheeling Charges
for FY 2020-21 to FY 2024-25
Particulars FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25
HT (Excl EHV) 1,714 1,737 1,796 1,822 1,848
LT Level 9,089 9,047 9,196 9,275 9,351
Total 10,804 10,784 10,992 11,097 11,199
8.29.18In addition to the allocation of yearly wheeling cost to recover projected ARR of wire
business through wheeling charge, the Commission in this present MYT Order has also
considered to recover the past period gaps (from FY 2017-18 to FY 2019-20) in recovery
of Wire ARR through Wheeling Charges to an extent of Rs 3528 Crore over the ensuing
years. Thus, proposed recovery of Wires cost (incl. deferred recovery of past period gaps
for wire business) for the ensuing years is provided in the following table:
Table 8-44: Total Wire Recovery including past period gaps for FY 2020-21 to FY 2024-25,
as approved by the Commission
FY 2020- FY 2021- FY 2022- FY 2023- FY 2024-
Particulars Units
21 22 23 24 25
Wheeling ARR Rs Cr 10,804 10,784 10,992 11,097 11,199
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Past Period Wheeling Gap (Incl. 657 657 657 657 657
Rs Cr
Carrying Cost)
Total Recovery (Incl. Past Gap) Rs Cr 11,461 11,441 11,650 11,754 11,856
8.29.19Thus, the voltage wise wheeled cost, wheeled units and approved Wheeling Charges so
determined for the 4th Control Period is summarised in the table below:
8.29.20In case of HT category where kVAh billing is introduced, Wheeling charges in Rs/kVAh
shall be applicable considering categorywise power factor (0.98 pf), as approved in the
above table. Further, the Commission approves Wheeling Loss of 7.5% at HT and 12% at
LT as proposed by MSEDCL.
8.29.21Further, In this Order, the Commission has also determined the Wires and Supply
components of the tariff separately for each consumer category. Accordingly, the Wheeling
Charge component and Energy Charge component have been shown separately while
computing the category-wise tariffs, except for the Residential BPL category. In case of the
BPL category, no Wheeling Charges are apportioned considering the consumer profile of
this category.
MSEDCL’s Submission
8.30.1 MSEDCL submitted that Section 2(47) of the said Electricity Act, 2003 defines “Open
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Access”, while the Section 42 of the said Act inter-alia mandates the Distribution Licensee
to provide Open Access to eligible consumers, subject to payment of “Cross Subsidy
Surcharge”, “Additional Surcharge” and other applicable charges.
8.30.2 Petitioner further submitted that the Section 42(2) of the Act provides for the levy of Cross
Subsidy Surcharge (CSS). The relevant provision of the Act is reproduced below:
“ …….. in determining the charges of wheeling, it shall have due regard to all
relevant factors including such cross-subsidies and other operational constraints;
Provided further that such surcharge shall be utilised to meet the requirements of
the current level of cross-subsidy within the area of distribution licensee”
Emphasis added
8.30.3 The Section 86(1)(a) of the said Act inter-alia mandates the Commission to determine
“Cross Subsidy Surcharge”, “Additional Surcharge” and other applicable charges payable
by the consumers opting for Open Access
8.30.4 Petitioner submitted that the National Electricity Policy as stipulated by the Central
Government provides that-
8.30.5 Petitioner submitted that the Central Government notified the revised National Tariff Policy
on 28th January 2016 and has revised the “Surcharge Formula” as follows:
S = T - [C/ (1 - L/ 100) + D + R]
Where,
S is the Surcharge
T is the Tariff Payable by the relevant category of consumers including reflection the
Renewable Purchase Obligation
C is the per unit weighted average cost of power purchase by the Licensee, including
meeting the Renewable Purchase Obligation
8.30.6 As per the provisions of Section 42(2) of the Electricity Act 2003, the cross-subsidy
surcharge needs to be based on the current level of cross subsidy. Accordingly, the
consumers who opted for open access needs to be charged for the compensation of current
level of cross subsidy which prevailed during the period and in order to avoid the burden of
the same getting passed on other consumers who are with the Distribution Licensee
8.30.7 Petitioner submitted that, to examine the issues related to Open Access along with issues
relating to amendments in provisions relating to captive Generating plants in the Electricity
Rules, 2005, a committee was constituted by CEA on the advice of Ministry of Power. In
the Consultation paper by MoP issued on 24th August 2017, which is based on the report
of the said Committee, it has been proposed that the SERCs should determine the CSS based
on real cross subsidy. The said Paper also advocated for implementation of Tariff Policy
2016 in true spirit. The relevant extract of the said Consultation Paper is reproduced below:
“The Tariff Policy 2016 mandates SERCs to determine roadmap for reduction of
cross subsidy and bring tariff at +/- 20% Average Cost of Supply, however it
restricts Cross Subsidy Surcharge at 20% of the consumer tariff. In case the
consumer tariff is more than 120% of Average Cost of Supply, DISCOM will not
be able to recover losses through cross subsidy surcharge in case consumer opts
for open access. It is essential for SERCs to implement both Para 8.3-2 and First
proviso to para 8.5.1 of the Tariff Policy 2016 simultaneously. If one of the
provisions could not be implemented due to some reason, the second provision
should also not be implanted to that extent.”
8.30.8 Petitioner further stated that while approving the CSS in Case No.195 of 2017, the
Commission worked out the various components of CSS formulae based on the approved
values for FY18-19 and FY19-20 and computed the consumer category-wise CSS in
accordance with the Tariff Policy 2016. The CSS computed in accordance with NTP
formulae represents the current level of cross subsidy. The Petitioner further stated that,
however, the Commission approved the CSS equal to minimum of the two values:
Computed CSS and 20% of tariff. This has resulted in lower CSS applicable than current
level of cross subsidy leading to incomplete recovery of cross subsidy from open access
consumers.
8.30.9 For example, the CSS calculated by the Commission as per the NTP formula for HT
industrial (general) at EHV level for FY 18-19 was Rs. 3.21 per unit whereas the CSS
approved for that category was Rs.1.58 per unit only. Considering the EHV Open Access
quantum for FY 18-19, the Petitioner lost about Rs.670 crores of legitimate revenue from
HT category open access consumers due to lower level of approved CSS.
8.30.10Petitioner thus submitted that such revenue deficit due to lower approved CSS is being
passed on to its consumers during truing-up exercise which results in:
• Substantial delay in revenue realisation which comes only after true up exercise
• Further tariff increases of MSEDCL consumers at large, despite not being at any
fault.
8.30.11OA consumers unduly get benefited due to less cross subsidy surcharge. As industrial
consumers are the subsidising consumers the impact gets loaded onto the industrial
category, raising its tariff. This increased industrial tariff will lead more consumers to opt
for open access which will further add to revenue deficit leading to requirement of further
tariff hike, thus entering a vicious cycle. Petitioner further states, therefore, as a principle,
only those consumers who opt for open access during a particular period should pay the
CSS for such period to maintain the prevailing level of cross subsidy and should not be
loaded onto the Petitioner’s consumers at large.
8.30.12Petitioner, thus, submitted that one of the reasons for tariff hike is incomplete recovery of
CSS. There can be no ambiguity with the preposition that CSS is a compensatory charge to
the Discom. This principle had been accepted even by the Appellate Tribunal in several
judgments earlier. Petitioner further submitted that, as held by the Tribunal, CSS is not only
to compensate the Discom for the loss of cross subsidy, it is also to compensate the
MERC Order – Case No. 322 of 2019 Page 571 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
remaining consumers of the Discom who have not taken open access. The same has been
held up in the APTEL in its judgement dated 2nd December 2013 in Appeal No.178 of 2011
(supra) which is reproduced below:
“…II The contention of the State Commission that Tariff Policy provide that the CSS
should not be enormous to suffocate the Competition is misplaced. The Act
mandated the State Commission to determine the CSS to meet the requirement of
current level of cross subsidy. We have to keep in mind that the CSS is paid by
subsidizing consumers only. This Tribunal in catena of cases has held that CSS is
compensatory in nature. It is meant for to compensate the loss suffered by the
remaining subsidised low-end consumers. Thus, in the scenario of mass changeover
of consumers, the CSS has also to be such that exodus of subsidizing consumers does
not load the remaining low-end consumers heavily. The State Commission has to
balance the interest of all the consumers, the plea taken by the State Commission in
Appeal No.132/2011 and accepted by this Tribunal in its judgement. The above
submission of the State Commission also suggests that it has attempted to suppress
the CSS artificially…” Emphasis Added
8.30.13Petitioner submitted that it has determined the cross-subsidy surcharge based on the Tariff
Policy formula without putting any ceiling.
8.30.15Computation of ‘C’ is based on the projected power purchase quantum and price for the
control period as submitted in the Form 2 of the Regulatory Formats for the respective year.
The definition/explanation for ‘C’ has been revised in the Tariff Policy dated 28th January
2016 with the inclusion of renewable power purchase in the computation of ‘C’. The
comparison of old and new Tariff Policy is given below:
Old Tariff Policy New Tariff Policy
Weighted average cost of power purchase of top Per unit weighted average cost of power
5% at the margin excluding liquid fuel-based purchase by the licensee, including meeting the
generation and renewable power. renewable purchase obligation.
8.30.16Petitioner submitted that the computation of ‘C’ can be taken as the total power purchase
cost based on MOD principle to the total power scheduled to be purchased as per the MOD
principle. Therefore, the ‘C’ computed for MSEDCL for control period are shown in the
following table:
8.30.17Computation of System Loss ‘L’: Petitioner submitted that the projected wheeling losses at
the respective voltage level and the transmission losses are used to arrive at the grossed up
total system losses for the Petitioner which is shown in the following table:
8.30.18Computation of Wheeling charge ‘D’: Petitioner submitted that the projected wheeling
charges as shown in the Chapter 11 at the respective voltage levels for the Petitioner along
with per unit transmission charges (including PGCIL charges and intra-state) are used for
the parameter ‘D’ in the computation of cross subsidy surcharge for the control period. The
same wheeling charges at respective voltage levels are shown in the following table along
with system losses:
Table 8-48: Computation of Wheeling Charge 'D' for the Control Period
Wheeling Charges and Transmission Charges
8.30.19Computation of Average Billing Rate ‘T’: Petitioner stated that its ABR has been taken as
the effective average billing rate as per the proposed tariff for control period
8.30.20Determination of Cross Subsidy Surcharge ‘S’: Petitioner submitted that the category wise
CSS applicable to open access consumers arrived on consideration of the components ABR,
C, L & D from the above referred respective sections is provided in the tables below:
HT I: HT – Industry
HT I(B): HT – Industry
(Seasonal)
HT II: HT – Commercial
HT III: HT –
Railways/Metro/Monorail
traction
HT V(B): HT – Agriculture
(Others)
T D=WL CSS
C WL TL L
(ABR) + Tx computed
Consumer Category
Rs./unit* % % % Rs./unit*
HT VIII(B): HT – Temporary
Supply Others (TSO)
LT Residential
LT I(B): LT – Residential
101 – 300 units 9.68 4.20 12.00% 3.30% 14.90% 2.37 2.37
301 – 500 units 12.32 4.20 12.00% 3.30% 14.90% 2.37 5.01
Above 500 units 13.15 4.20 12.00% 3.30% 14.90% 2.37 5.85
LT II: LT – Non-Residential
(B) > 20 kVA and ≤ 50 kVA 13.39 4.20 12.00% 3.30% 14.90% 2.37 6.08
T D=WL CSS
C WL TL L
(ABR) + Tx computed
Consumer Category
Rs./unit* % % % Rs./unit*
(C) > 50 kVA 15.35 4.20 12.00% 3.30% 14.90% 2.37 8.04
LT IV(C): LT – Agriculture
7.95 4.20 12.00% 3.30% 14.90% 2.37 0.65
Metered – Others
LT V(A): LT – Industry –
Powerlooms
(ii) Above 20 kVA 7.87 4.20 12.00% 3.30% 14.90% 2.37 0.56
LT V(B): LT – Industry –
General
(ii) Above 20 kVA 9.22 4.20 12.00% 3.30% 14.90% 2.37 1.92
(B): Municipal Corporation area 7.76 4.20 12.00% 3.30% 14.90% 2.37 0.45
LT VII: LT – Temporary
Connection
LT VIII: LT – Advertisements
20.39 4.20 12.00% 3.30% 14.90% 2.37 13.08
and Hoardings
(ii) > 20 kVA and ≤ 50 kVA 8.72 4.20 12.00% 3.30% 14.90% 2.37 1.41
(iii) > 50 kVA 9.80 4.20 12.00% 3.30% 14.90% 2.37 2.50
(ii) > 20 kVA and ≤ 50 kVA 10.65 4.20 12.00% 3.30% 14.90% 2.37 3.34
T D=WL CSS
C WL TL L
(ABR) + Tx computed
Consumer Category
Rs./unit* % % % Rs./unit*
(iii) > 50 kVA 10.85 4.20 12.00% 3.30% 14.90% 2.37 3.54
HT I: HT – Industry
HT II: HT – Commercial
HT III: HT – Railways/Metro/Monorail
traction
EHV - - - - -
FY FY FY FY FY
2020-21 2021-22 2022-23 2023-24 2024-25
Consumer Category
Rs./unit Rs./unit Rs./unit Rs./unit Rs./unit
EHV - - - - -
EHV - - - - -
EHV - - - - -
Table 8-52: Summary of CSS for the Control Period for LT Consumers
FY FY FY FY FY
2020-21 2021-22 2022-23 2023-24 2024-25
Consumer Category
Rs./unit Rs./unit Rs./unit Rs./unit Rs./unit
LT Residential
LT I(B): LT – Residential
1 – 100 units - - - - -
FY FY FY FY FY
2020-21 2021-22 2022-23 2023-24 2024-25
Consumer Category
Rs./unit Rs./unit Rs./unit Rs./unit Rs./unit
(B) > 20 kVA and ≤ 50 kVA 6.08 6.76 7.00 7.24 7.55
(A) 0 – 20 kVA - - - - -
(A): LT – Temporary Supply Religious (TSR) 0.75 1.73 2.35 3.08 3.98
(B): LT – Temporary Supply Others (TSO) 9.01 10.04 10.68 11.39 12.22
FY FY FY FY FY
2020-21 2021-22 2022-23 2023-24 2024-25
Consumer Category
Rs./unit Rs./unit Rs./unit Rs./unit Rs./unit
(i) 0 – 20 kVA - - - - -
(ii) > 20 kVA and ≤ 50 kVA 1.41 2.00 2.15 2.31 2.63
(ii) > 20 kVA and ≤ 50 kVA 3.34 4.11 4.46 4.81 5.22
8.30.21Petitioner submitted that as stipulated in the Open Access Regulations, the cross-subsidy
surcharge shall be based on the current level of cross subsidy of the tariff category/ tariff
slab and/or voltage level to which such consumer or person belong or are connected to.
Accordingly, the consumers who opt for Open Access during the control period need to be
charged to compensate the level of cross subsidy which will prevail during the control
period and to avoid the burden of the same on other consumers. Petitioner, therefore,
requested the Commission to approve the CSS for the control period as computed above.
8.30.22The Commission has taken a note of the concern raised by MSEDCL regarding the
application of ceiling cap of +/- 20% across consumer categories as per the Para. 8.3 (2) of
the Tariff Policy, 2016. Further, the Commission also notes the reference to the Consultation
Paper issued by MoP in August, 2017 as regards implementation of both Para. 8.3 (2) and
first proviso to para 8.5.1. of the Tariff Policy, 2016 simultaneously.
8.30.23The Commission here would like to highlight that, while working out the CSS, in the
previous MTR order in Case No. 195 of 2017, basic intent of keeping the cap of +/- 20%
was to keep the gradual reduction trend of the cross-subsidy over the ensuing years and
MERC Order – Case No. 322 of 2019 Page 581 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
determine the tariff as close as is possible to the ACoS as well as keeping the cognizance
of avoiding tariff shock all across the consumer categories. Further, the Commission notes
that in case of most prominent consumer category that is eligible for Open Access and avails
open access i.e. HT-Industry, the ratio of ABR/ACoS is lower than 120%.
8.30.24Thus, Commission has worked out the CSS by keeping the ceiling of +/- 20% for most of
the consumer categories in order to maintain the consistency with the principle adopted in
the previous MTR Order.
8.30.25Further, the Commission has worked out the various components of CSS formulae based
on the approved values for 4th Control Period and worked out the category-wise CSS for
4th Control Period i.e. from FY 2020-21 to FY 2024-25 for HT Consumers only, since the
eligible consumers for OA lies within the HT consumers category only.
20%
D= CSS CSS
T of
C TL WL L WL + Computed - Min
Consumer Category (ABR) Tariff
Tx -a (a,b)
- (b)
Rs./Unit* % % % Rs./Unit* Rs./Unit*
HT IV: HT - Public Water Works
7.39 4.00 3.18% 7.50% 10.44% 1.40 1.52 1.48 1.48
(PWW)
HT V(A): HT - Agriculture
4.74 4.00 3.18% 7.50% 10.44% 1.40 - 0.95 -
Pumpsets
HT V(B): HT - Agriculture Others 6.01 4.00 3.18% 7.50% 10.44% 1.40 0.14 1.20 0.14
HT VI: HT - Group Housing
7.27 4.00 3.18% 7.50% 10.44% 1.40 1.40 1.45 1.40
Societies (Residential)
HT VIII(B): HT - Temporary
14.30 4.00 3.18% 7.50% 10.44% 1.40 8.43 2.86 2.86
Supply Others (TSO)
HT IX(A): HT - Public Services-
Govt. Edu. Institutions and 9.28 4.00 3.18% 7.50% 10.44% 1.40 3.41 1.86 1.86
Hospitals
HT IX(B): HT - Public Services-
9.28 4.00 3.18% 7.50% 10.44% 1.40 3.41 1.86 1.86
Others
HT X: HT – Electric Vehicle
8.29 4.00 3.18% 7.50% 10.44% 1.40 2.42 1.66 1.66
Charging Station
Table 8-54: Cross Subsidy Surcharge approved by Commission for FY 2021-22 as per
revised Tariff Policy, 2016
D= CSS 20% of CSS -
T
C TL WL L WL + Computed Tariff - Min
Consumer Category (ABR)
Tx -a (b) (a,b)
Rs./Unit* % % % Rs./Unit* Rs./Unit*
HT Category - EHV (66kV and Above)
HT I (A) (i): HT - Industry 8.37 4.00 3.18% 0.00% 3.18% 0.82 3.41 1.67 1.67
HT I (B): HT - Industry
11.14 4.00 3.18% 0.00% 3.18% 0.82 6.19 2.23 2.23
(Seasonal)
HT II (A): HT - Commercial 14.47 4.00 3.18% 0.00% 3.18% 0.82 9.51 2.89 2.89
HT III (A): HT -
Railways/Metro/Monorail 7.19 4.00 3.18% 0.00% 3.18% 0.82 2.23 1.44 1.44
Traction
HT IV: HT - Public Water
6.84 4.00 3.18% 0.00% 3.18% 0.82 1.88 1.37 1.37
Works (PWW)
HT V(A): HT - Agriculture
3.87 4.00 3.18% 0.00% 3.18% 0.82 - 0.77 -
Pumpsets
HT VI: HT - Group Housing
5.70 4.00 3.18% 0.00% 3.18% 0.82 0.74 1.14 0.74
Societies (Residential)
HT IX(B): HT - Public
9.90 4.00 3.18% 0.00% 3.18% 0.82 4.95 1.98 1.98
Services-Others
HT Category - HT (33kV, 22kV and 11 kV)
HT I (A) (i): HT - Industry 8.53 4.00 3.18% 7.50% 10.44% 1.38 2.68 1.71 1.71
HT I (B): HT - Industry
10.28 4.00 3.18% 7.50% 10.44% 1.38 4.43 2.06 2.06
(Seasonal)
HT II (A): HT - Commercial 13.26 4.00 3.18% 7.50% 10.44% 1.38 7.40 2.65 2.65
HT III (A): HT -
Railways/Metro/Monorail 8.55 4.00 3.18% 7.50% 10.44% 1.38 2.69 1.71 1.71
Traction
MERC Order – Case No. 322 of 2019 Page 583 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
Table 8-55: Cross Subsidy Surcharge approved by Commission for FY 2022-23 as per
revised Tariff Policy, 2016
Table 8-56: Cross Subsidy Surcharge approved by Commission for FY 2023-24 as per
revised Tariff Policy, 2016
D= CSS 20% of CSS -
T
C TL WL L WL + Computed Tariff - Min
Consumer Category (ABR)
Tx -a (b) (a,b)
Rs./Unit* % % % Rs./Unit* Rs./Unit*
HT Category - EHV (66kV and Above)
HT I (A) (i): HT - Industry 7.98 4.00 3.18% 0.00% 3.18% 0.81 3.04 1.60 1.60
HT I (B): HT - Industry
13.31 4.00 3.18% 0.00% 3.18% 0.81 8.37 2.66 2.66
(Seasonal)
HT II (A): HT - Commercial 14.16 4.00 3.18% 0.00% 3.18% 0.81 9.22 2.83 2.83
HT III (A): HT -
Railways/Metro/Monorail 7.52 4.00 3.18% 0.00% 3.18% 0.81 2.58 1.50 1.50
Traction
HT IV: HT - Public Water
6.69 4.00 3.18% 0.00% 3.18% 0.81 1.75 1.34 1.34
Works (PWW)
HT V(A): HT - Agriculture
3.96 4.00 3.18% 0.00% 3.18% 0.81 - 0.79 -
Pumpsets
HT VI: HT - Group Housing
5.20 4.00 3.18% 0.00% 3.18% 0.81 0.26 1.04 0.26
Societies (Residential)
HT IX(B): HT - Public
8.49 4.00 3.18% 0.00% 3.18% 0.81 3.55 1.70 1.70
Services-Others
HT Category - HT (33kV, 22kV and 11 kV)
HT I (A) (i): HT - Industry 8.61 4.00 3.18% 7.50% 10.44% 1.35 2.79 1.72 1.72
Table 8-57: Cross Subsidy Surcharge approved by Commission for FY 2024-25 as per
revised Tariff Policy, 2016
8.30.27With the rationalisation effected by the Distribution Open Access Regulations, 2016 and its
First amendment thereof, adoption of the CSS formulae in accordance with the Tariff Policy
and the preferential tariff approved for purchase from RE sources, no concession would be
provided to the RE sector in terms of discounted CSS levy. Thus, from the date of
applicability of this Order, in case of an OA consumer purchases power from a RE source,
the full CSS as determined above shall be payable. The CSS so approved as above shall be
applicable on the energy actually consumed by the OA consumer, i.e., on the metered
consumption.
MSEDCL’s Submission
8.31.1 MSEDCL submitted that Section 42(4) provides the levy of Additional Surcharge to a
consumer who receives supply of electricity from a person other than the distribution
licensee of his area of supply. Regulation 14.8 of the Commission’s Distribution OA
Regulations, 2016 outlines the principles for determination and levy of Additional
Surcharge as below:
8.31.2 MSEDCL submitted that it has been casted by Universal Service Obligation (USO) under
the Section 43 of the Electricity Act 2003. Hence, in order to cater to the consumer demand,
it has to purchase power on long term basis from Mahagenco, NTPC under the MoU route
and from IPPs through competitive bidding process. Petitioner further submitted that the
tariff for generation as per PPA/MoU comprises of two parts viz. Fixed Charge which is
dependent on declared availability of generator and variable charge which is dependent on
declared availability of generator and variable charge which is dependent on actual energy
supplied.
8.31.3 MSEDCL submitted that capacity addition was done by signing the PPAs with generating
companies after due approval of the Commission and based on estimated demand as per the
projections published in 16th Electric Power Survey (EPS) published by CEA. However,
there is a variation in projected and actual demand due to various reasons such as increase
in Open Access, RE capacity addition to fulfil RPO Target, RE capacity addition by CPP
because of low tariff and Net Metering etc., resulting into surplus power availability.
8.31.4 MSEDCL further submitted that to fulfil the RPO targets set by the Commission, it has to
plan prospective power purchase from RE sources. MSEDCL submitted that it has to
procure at least 25% of the power from Renewable sources by FY2024-25 which include
13.5% of solar and 11.5% of non-solar power, as per RPO Regulations 2019 notified on
27th December 2019. Hence, MSEDCL has tied up a total of 10,785 MW capacity of
Renewable Energy as on 31st October 2019 of which 7654 MW capacity is commissioned,
which include wind generation of 3999 MW, solar of 4017 MW, bagasse based
cogeneration of 2406 MW, biomass capacity of 236 MW, small hydro of 121 MW and
Municipal Solid Waste of 16 MW capacity. Further, by the end of FY 2024-25 to meet RPO
target, MSEDCL has planned to increase the solar capacity to 12,500 MW. Due to such
addition of renewable power, the surplus power is expected to be continued further since
the renewable energy is treated as “Must Run”.
8.31.5 MSEDCL also submitted that due to recent trends in the prices of solar energy and MERC
Net Metering Regulations 2019, various consumers are now converting to captive power
plants (CPPs) by installing solar projects through developers, hence, surplus power is also
expected to increase further.
8.31.6 MSEDCL also submitted that to manage surplus power, MSEDCL gives zero
schedule/backdown to the high variable cost thermal generation as per Merit Order
Despatch or sell in energy market depending upon market rates thereby reducing the burden
MERC Order – Case No. 322 of 2019 Page 588 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
of energy charges. MSEDCL further submitted that it has to pay fixed/capacity charges
irrespective of the scheduling or non-scheduling of power from the units which declare its
availability whenever surplus capacity remains available.
8.31.7 MSEDCL further submitted that whenever there is unavailability of generation due to the
forced outage/coal shortage, there is requirement of additional power during certain blocks
of the day, sometimes the duration of shortfall during the day is so small that to cater the
demand for such small period, it is unviable to take a generation unit on bar to cater the
demand for small period. In such cases, the Petitioner forecasts the demand, availability and
shortfall on day-ahead basis and procures power from Short Tern Markets such as Energy
Exchanges.
8.31.8 MSEDCL also submitted that it has to plan in advance and procure the power on short term
through bilateral transactions on DEEP Portal considering the historical trend of demand,
coal shortage scenario, trend of rates in exchanges, etc.
8.31.9 MSEDCL submitted that it also explores the option of optimisation of power purchase cost
by backing down of costly generation unit as per MOD and procuring the cheaper power
available in Short Term Market/Exchange.
8.31.10MSEDCL further submitted that it has to pay fixed charges to the generators as per the terms
and conditions of the PPAs irrespective of utilisation of generation capacity and thus it gets
burdened by fixed cost of surplus capacity.
8.31.11MSEDCL submitted the year wise details of net surplus capacity, backdown quantum
capacity under outages due to coal shortage and power purchase through short term tender
and IEX is as given in the following tables:
A B C=A+B D
Average MW on
2095 1306 3401 460
RTC basis
A B C=A+B D
Average MW on
2384 1781 4165 665
RTC basis
A B C=A+B D
Average MW on
3893 159 4052 130
RTC basis
8.31.12 MSEDCL submitted that MSEDCL is in power surplus as reflected from above tables and
will continue to be in surplus for the 4th control period. However, short term power is
purchased for cost optimization or to meet demand during coal shortage scenario and hence,
additional surcharge is justifiable & needs to be made applicable to all OA consumers.
Surcharge Computation as submitted by MSEDCL
8.31.13MSEDCL submitted that it has implemented Intra State ABT in Maharashtra since 1st
August 2011 and SLDC/ Discom are granting approvals/ consent to open access consumers
for purchase and sale of power through open access as per Open Access Regulations.
MSEDCL further submitted that open access consumers are buying considerable quantum
of power under open access and on the other hand, it has tied up sufficient quantum of power
after approval of the Commission to meet the expected demand by considering the overall
growth in the state.
8.31.14MSEDCL also submitted that it needs to back down the generation and also has to pay Fixed
Charges (or Capacity Charges) to the Generators as per the terms and conditions of the PPAs
irrespective of utilization of generation capacity, when the tied up generation capacity
becomes excess and that the burden of fixed cost is affecting the viability and sustainability
of its operations, which ultimately adversely affects the tariff of its common consumers.
8.31.15MSEDCL submitted that it has calculated the Additional Surcharge for the 4th control period
i.e. FY2020-21 to FY2024-25 as per DOA Regulations 2016 based on the data for the
FY2018-19 as per the methodology adopted by the Commission in the MYT Order dated
3rd November 2016 and MTR Order dated 12th September 2018.
Table 8-58: Additional Surcharge for FY 2020-21 as submitted by MSEDCL
Particulars Reference Unit Value
Fixed cost of thermal generating sources for FY2020-21 (d) Rs. Crs 19,207
Projected Open Access volume for year for FY2020-21 (h) MUs 4843
Fixed cost of thermal generating sources for FY2021-22 (d) Rs. Crs 19,698
Projected Open Access volume for year for FY2021-22 (h) MUs 4843
Fixed cost of thermal generating sources for FY2022-23 (d) Rs. Crs 20,038
Projected Open Access volume for year for FY2022-23 (h) MUs 4843
Fixed cost of thermal generating sources for FY2023-24 (d) Rs. Crs 20,487
Projected Open Access volume for year for FY2023-24 (h) MUs 4843
Fixed cost of thermal generating sources for FY2024-25 (d) Rs. Crs 20,276
Projected Open Access volume for year for FY2024-25 (h) MUs 4843
Table 8-63: Summary of Additional Surcharge for 4th Control Period as proposed by
MSEDCL
Proposed Additional
1.33 1.37 1.40 1.43 1.42
Surcharge (Rs/kVAh)
8.31.16MSEDCL has requested the Commission to approve the Additional Surcharge for Open
Access consumers irrespective of source i.e. Captive Power Plants (CPPs), IPP, RE based
power plants etc. in addition to the conventional open access consumers as computed in the
above tables.
8.31.17MSEDCL further submitted that the CPPs existing prior to FY2015-16 originally set up the
plant for self-consumption and continuing the same arrangement of captive use shall be
exempted from applicability of Additional Surcharge. This is since these were set up during
the power shortage situation and were captive in real sense as per the spirit of the Act.
Commission’s Analysis and Ruling
8.31.18The Commission has carefully examined the submissions of MSEDCL, as well as the
objections filed by stakeholders with regard to the determination of Additional Surcharge
and MSEDCL’s replies. The Commission has examined the Section 42(4) of the EA, 2003,
Clause 8.5.4 of the Tariff Policy, 2016 and Regulation 14.8 of the Distribution Open Access
Regulations, 2016 (‘DOA Regulations, 2016’). In light of said provisions of the respective
Regulations and Tariff Policy, the Commission in its MYT Order and MTR had already
recognised that there is a case for recovery of the part of fixed cost towards the stranded
capacity arising from the power purchase obligation through levy of Additional Surcharge
from OA consumers.
8.31.19As the Commission has envisaged a power surplus scenario for 4th Control Period, the levy
of Additional Surcharge from OA consumers is found to be applicable for FY 2020-21 to
FY 2024-25.
8.31.20Regarding the applicability of the Additional Surcharge, MSEDCL stated that the
Additional Surcharge, being a compensatory amount payable towards the fixed cost of
stranded power resulting from approved power purchase contracts, has to be determined
commonly for all the OA Users.
8.31.21The Commission has examined the relevant provisions of EA, 2003, and Regulation 14.8
of the DOA Regulations, 2016 on which MSEDCL has relied. The relevant extracts read as
follows:
“(a) Section 42 (4) of EA, 2003, stipulates that:
“Where the State Commission permits a consumer or class of consumers to receive
supply of electricity from a person other than the distribution licensee of his area of
supply, such consumer shall be liable to pay an additional surcharge on the charges
of wheeling, as may be specified by the State Commission, to meet the fixed cost of
such distribution licensee arising out of his obligation to supply.”
8.31.22The Second proviso of Section 9 (1) of the EA 2003 only states that the electricity generated
from Captive Generating Plants (CGP) may be supplied to any consumers subject to
Regulations made under Section 42 (2) of the EA 2003. The Relevant para. is reproduced
as below:
“9.
(1) Notwithstanding anything contained in this Act, a person may construct, maintain
or operate a captive generating plant and dedicated transmission lines:
Provided that the supply of electricity from the captive generating plant through the
grid shall be regulated in the same manner as the generating station of a generating
company.
[Provided further that no licence shall be required under this Act for supply of
electricity generated from a captive generating plant to any licencee in accordance
with the provisions of this Act and the rules and regulations made thereunder and to
any consumer subject to the regulations made under subsection (2) of section 42.
(2) Every person, who has constructed a captive generating plant and maintains and
operates such plant, shall have the right to open access for the purposes of carrying
electricity from his captive generating plant to the destination of his use:”
8.31.231st proviso to Regulation 14.8 (d) of DOA Regulations, 2016 reads as follows:
“14.8 (d)… (ii) The cost has not been or cannot be recovered from the consumer, or
from other consumers who have been given supply from the same assets or facilities,
or from other Consumers, either through wheeling charges, standby charges or such
other charges as may be approved by the Commission:
Provided that such Additional Surcharge shall be applicable to all the consumers who
have availed Open Access to receive supply from a source other than the Distribution
Licensee to which they are connected.”
wheeling, it shall have due regard to all relevant factors including such cross
subsidies, and other operational constraints:
…..
Provided also that such surcharge shall not be leviable in case open access is provided
to a person who has established a captive generating plant for carrying the electricity
to the destination of his own use:”
8.31.25Moreover, CSS and Additional Surcharge are levied on account of completely different
underlying principles. CSS is used/ utilized/ levied to meet the requirement of current level
of cross subsidy of Distribution Licensee, while Additional Surcharge is to be levied to meet
the fixed cost of such Distribution Licensee arising out of his obligation to supply and its
planned power supply has been stranded due to shifting/switching over of Consumers from
Distribution Licensee to Open Access mode.
8.31.26The Commission is of the considered view that, unless fixed costs due to stranded capacity
are recovered from OA Consumers, this burden would be unjustly loaded onto other
Consumers of Distribution Licensee. The Commission believes it would be unfair and
unwarranted to pass such burden of fixed cost recovery of such stranded cost to other
Consumers through consequent tariff hike.
8.31.27The Commission is of the view that, under the circumstances and in pursuance of Regulation
14.8 of the DOA Regulations, 2016, there is a case for recovery of the part of fixed cost
towards the stranded capacity arising from the power purchase obligation through levy of
Additional Surcharge from OA Consumers including the Group Captive Consumers who
have availed such arrangement.
8.31.28Accordingly, the Commission in its MTR Order in Case No.- 195 of 2017 dated 12
September 2018 had determined the two categories of captive users who procure power
from CGP’s viz., (a) Original Captive Users (who were never consumers of Distribution
Licensee) and (b) Converted Captive Users (who subsequently switchover to GCPP mode)
. The Original Captive Users were the Users who have been procuring power originally
under the captive mode and whose demand has not been included in the power procurement
plan of Distribution Licensee whereas Converted Captive Users are the Users who prior to
issue of MTR Order dated 12 September 2018 were Consumers of Distribution Licensee
and who have opted to procure power under Group Captive arrangement, creating stranded
capacity for Distribution Licensee. In view of the above the Commission held that
Additional Surcharge shall be applicable to Captive Users of Group Captive Power Plants;
in addition to Open Access consumers in Case No. - 195 of 2017 dated 12 September 2018.
MERC Order – Case No. 322 of 2019 Page 597 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
8.31.29However, APTEL in Appeal No. 311 of 2018 & IA Nos. 1531, 1468 & 1467 of 2018 dated
27th March 2019 filed by JSW Steel Limited and others had set aside the Commission’s
Order in Case No. - 195 of 2017 dated 12 September 2018 against the levy of additional
surcharge on Captive Users of Group Captive Power Plants. The relevant extracts of the
Judgement is reproduced below for reference:
“83. The scope of Mid Term Review proceedings is understood from the above
regulations. As seen from the above Regulations, the Commission cannot deviate from
the principles adopted in the Multi Year Tariff order. Fundamental principles adopted
in the MYT proceedings cannot be reopened and challenged at the stage of MTR
proceeding, the scope of which is very limited.
84…
85. There is one more flaw in the manner in which the Respondent Commission
proceeded with Mid-Term-Performance Review. Having come to conclusion that
captive consumers are not liable to pay additional surcharge in MYT proceedings,
which was implemented by MSEDCL, MERC opines in Review Proceedings that
additional surcharge is payable by captive consumers of captive power plant. But this
is without giving an opportunity of being heard to the Appellants. This is nothing but
violation of principles of natural justice. Firstly, Mid-Term Review is nothing but a
comparison between the actual operational performances (factual) vis-a-vis the
approved forecast in terms of MERC regulations of 2015. This is nothing but ignoring
its own regulations.
86…
88. In the light of the above discussion and reasoning, we are of the opinion that there
cannot be any distinction between an individual captive consumer and group captive
consumers or original captive consumers and converted captive consumers. For the
above mentioned reasons, the above appeals deserve to be allowed and accordingly
allowed. The impugned order dated 12.09.2018 passed by Maharashtra Electricity
Regulatory Commission is hereby set aside. All the pending IAs shall stand disposed
of. No order as to costs.”
8.31.30However, the Supreme Court in its Record of Proceedings dated 01.07.2019 in Civil Appeal
No(s). 5074-5075/2019 has put stay on operation and implementation of APTEL’s
Judgement in Appeal No. 311 of 2018 & IA Nos. 1531, 1468 & 1467 of 2018 dated 27th
March 2019.
not been included in the power procurement plan of Distribution Licensee whereas
Converted Captive Users are the Users who prior to issue of MTR Order Case No. - 195 of
2017 dated 12 September 2018 were Consumers of Distribution Licensee and who have
opted to procure power under Group Captive arrangement, creating stranded capacity for
Distribution Licensee.
8.31.32However, as quantum of consumption by such GCPP users is not known and matter being
sub-judice, the Commission has not considered revenue projections from such Additional
Surcharge in case of GCPP users. The same would be subject to scrutiny and prudence
check at the time of MTR.
8.31.33In view of the above the Commission holds that for 4th Control Period, Additional Surcharge
shall be applicable to Captive Users of Group Captive Power Plants, in addition to Open
Access consumers.
8.31.34The Commission has employed the same methodology as suggested by the MSEDCL for
determination of the Additional Surcharge for 4th Control Period, the computation of which
is provided below.
Table 8-64: Additional Surcharge for FY 2020-21 approved by the Commission (Rs/kWh)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Step-1: Establishing contribution of OA to backing-down/stranded capacity
OA volume for FY 2019-20 (Upto Sept-19) (a) MU 2,178 2,159
Backing Down quantum for FY 2019-20
(b) MU 14,704 14,704
(Upto Sept-19)
Ratio to OA to Backed down for FY 2019-
(c )=(b)/(a) % 14.81% 14.68%
20 (Upto Sept-19)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Table 8-65: Additional Surcharge for FY 2021-22 approved by the Commission (Rs/kWh)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Step-1: Establishing contribution of OA to backing-down/stranded capacity
OA volume for FY 2019-20 (Upto Sept-19) (a) MU 2,178 2,159
Backing Down quantum for FY 2019-20
(b) MU 14,704 14,704
(Upto Sept-19)
Ratio to OA to Backed down for FY 2019-
(c )=(b)/(a) % 14.81% 14.68%
20 (Upto Sept-19)
Table 8-66: Additional Surcharge for FY 2022-23 approved by the Commission (Rs/kWh)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Step-1: Establishing contribution of OA to backing-down/stranded capacity
OA volume for FY 2019-20 (Upto Sept-19) (a) MU 2,178 2,159
Backing Down quantum for FY 2019-20
(b) MU 14,704 14,704
(Upto Sept-19)
Ratio to OA to Backed down for FY 2019-
(c )=(b)/(a) % 14.81% 14.68%
20 (Upto Sept-19)
Table 8-67: Additional Surcharge for FY 2023-24 approved by the Commission (Rs/kWh)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Step-1: Establishing contribution of OA to backing-down/stranded capacity
OA volume for FY 2019-20 (Upto Sept-19) (a) MU 2,178 2,159
Backing Down quantum for FY 2019-20
(b) MU 14,704 14,704
(Upto Sept-19)
Ratio to OA to Backed down for FY 2019-
(c )=(b)/(a) % 14.81% 14.68%
20 (Upto Sept-19)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Fixed Cost of Thermal Generating Sources
(d) Rs. Crs 21,670 21,307
for FY 2023-24
Total Available MU from Thermal
(e ) MUs 129,091 172,536
Generating Stations for FY 2023-24
Wt. Avg. Per Unit FC of Thermal (f)=(d)/(e )
Rs/kWh 1.68 1.23
Generating Stations for FY 2023-24 x10
Total Projected Backdown/RSD Volume
(g) MUs 16,364 16,364
for FY 2023-24
Projected Open Access Volume for year for
(h) MUs 4,843 4,843
FY 2023-24
Fixed Cost pertaining to Backdown/RSD
(i)=(f)*(h)/10 Rs. Crs 813 598
capacity for FY 2023-24
Table 8-68: Additional Surcharge for FY 2024-25 approved by the Commission (Rs/kWh)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Step-1: Establishing contribution of OA to backing-down/stranded capacity
OA volume for FY 2019-20 (Upto Sept-19) (a) MU 2,178 2,159
Backing Down quantum for FY 2019-20
(b) MU 14,704 14,704
(Upto Sept-19)
Ratio to OA to Backed down for FY 2019-
(c )=(b)/(a) % 14.81% 14.68%
20 (Upto Sept-19)
Approved
MYT
Particulars Reference Unit in this
Petition
Order
Table 8-69: Summary of Additional Surcharge for 4th Control Period as approved by the
Commission (Rs/kWh)
8.31.35The Commission observes that for application of the Additional Surcharge, it has to be
conclusively demonstrated that the contracted capacity has been stranded and that open
access has partly resulted in causing such stranded capacity. Based on actual data for FY
2019-20 (Upto September 2019) and the workings provided in the above table, the case of
stranded capacity on account of open access and hence the levy of Additional Surcharge is
established. Besides, based on the approved power purchase projections and projection of
available generation capacity as outlined under Chapter-6, the same is expected to continue
for 4th Control Period. Hence, for the purpose of specifying the additional surcharge for the
future years of 4th Control period, the Commission approves the Additional Surcharge as
per the above mentioned table.
8.31.36However, for the purpose of billing, as kVAh based billing has been introduced for HT
category consumers, Additional Surcharge (in kVAh terms) shall be applicable by
multiplying category-wise power factor (0.98 pf) to be applied on Additional Surcharge (in
per Rs/ kWh) so determined in above tables for respective years of the 4th Control Period.
Directive
9.1.1 MSEDCL at the time of last MTR process submitted that out of 4901 Agricultural feeders
with AMR, only 1021 feeders are active and the rest are having communication linkage
problem. MSEDCL was directed to keep all the feeder AMR active and start uploading data
on its website.
MSEDCL’s Response
9.1.2 MSEDCL submitted that as on 25th November 2019, out of the total 5405 Ag feeders, 5228
nos. have been upgraded with AMR facilities. MSEDCL submitted that it is rigorously
taking up the process to install AMR for the balance 177 nos. MSEDCL also submitted that
the feeder input data for all the feeders (including Ag feeders) is made available at MSEDCL
website on following path:
Consumer Portal > Operational data > Feeder Input Data
(https://consumerinfo.mahadiscom.in/feederdata/index.php)
Commission’s Ruling
9.1.3 The Commission has noted MSEDCL’s submission and progress on compliance of the
directive. MSEDCL shall ensure that various actions points including metering of AG
feeders as listed under para 4.2.25 shall be carried out.
Directive
9.2.1 MSEDCL to educate the consumers and take all necessary steps to ensure that all the
consumers are billed by kVAh method from the next MYT i.e. from 1st April 2020.
MSEDCL’s Response
9.2.2 MSEDCL submitted that it has taken up necessary steps to ensure smooth rollout of kVAh
billing. Consumer awareness programs were conducted. FAQs on kVAh billing were
uploaded on the website and many interactive sessions on the same were conducted. The
consumer awareness programs received many interest from the consumers and were
successfully coordinated.
MERC Order – Case No. 322 of 2019 Page 604 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
9.2.3The next step towards kVAh metering was meter replacement. MSEDCL submitted that it
has already initiated meter replacement and the same for HT consumers is planned to be
completed by January 2020. After completing HT meter replacement, MSEDCL will
rigorously take up LT meter replacement too. MSEDCL further submitted that the status of
the same would be communicated to the Commission during the next MTR process.
Commission’s Ruling
9.2.4 The Commission has noted compliance of the MSEDCL in the matter and the progress for
adoption of kVAh-based billing for HT consumer categories. The Commission also
observes that MSEDCL has chalked out clear plans to shift LT consumes also to kVAH
regime. The Commission intends to implement kVAh billing to all LT consumers having
load above 20 kW from 1 April, 2023 upon review of implementation of kVAH based
billing for HT consumers effective from 1st April, 2020. MSEDCL is required to take
necessary steps such as meter replacement, if required, preparedness of billing software etc.
for smooth implementation of kVAh billing.
10 SCHEDULE OF CHARGES
10.1 Background
10.1.1 MSEDCL has submitted that it recovers various miscellaneous and general charges from its
consumers for various services provided as per the Schedule of charges approved by the
Commission vide its Order dated 12 September, 2018 (Case No. 195 of 2017). Basically,
these charges are for recovery of cost incurred for availing supply of electricity and various
other services provided to the consumers. In order to shield regular consumers from
consumer service specific costs, provision for schedule of charges has been made. Income
from these charges form a part of the non-tariff income of MSEDCL.
10.1.2 MSEDCL stated that the provisions of Section 46 of the Act provides that the Commission
may authorize a Distribution License to charge a person requiring a supply of electricity
any expenses reasonably incurred in providing any electric line or electrical plant used for
the purpose of giving that supply. Otherwise these costs will get passed on to regular
consumers of MSEDCL.
10.1.3 MSEDCL also quoted provisions of Supply Code Regulations where various charges are
permitted to be recovered from consumers subject to approval from the Commission.
Various services for which charges can be recovered from the consumer as per provisions
in MERC (Electricity Supply Code) Regulations, 2005.
10.1.4 In its Petition, MSEDCL has prayed to revise the schedule of charges and proposed revised
charges. In the following paragraphs, the Commission has analysed the proposal and
determined the Schedule of Charges for MSEDCL.
10.2.1 MSEDCL submitted that it has proposed Service Connection Charges (SCC) based on
maximum of estimated or actual expenditure incurred for providing supply to the consumer.
10.2.2 The Commission in its Order in Case No. 197 of 2017 dated 12 September, 2018 has
estimated the service connection charges on the basis of 20 meters as the average length.
MSEDCL in present proposal has followed the same basis for estimation.
10.2.3 MSEDCL submitted that it has used the material schedule rates of its Central Purchase
Agency (CPA). As per revised Cost data of FY 2019-20 and centages, the estimates are
prepared to derive the Service Connection charges. The loading - unloading and handling
charges for meter, Contingencies, Insurance of material & price variation/ escalation were
taken in consideration. The centages in total over the total estimated cost of materials is
25.50%. All other things are kept as it is such as supervision charges, variable charges etc.
10.2.4 While estimating charges for new HT Overhead connection, MSEDCL has considered all
the legitimate expenditure for works of Gantry, Earthing, protection and Metering etc.
Similar works have been considered in case of HT underground new service connection.
Accordingly, MSEDCL proposes the new service connection charges based on all
legitimate costs.
10.2.5 The computation of service connection charges for new overhead connections as submitted
by MSEDCL is detailed below:
LT supply
Single phase:
Table 10-2: Service connection charges for Overhead connection (LT 1 Ph)
Three phase:
Table 10-3: Service connection charges for Overhead connection (LT 3 Ph) for motive
power (< 27 HP) or other (< 20 kW) as proposed by MSEDCL
Material Unit Quantity Rate in Rs Cost in Rs
10-40A LTAC Three Phase
6loWPAN RF Meter with No. 1 1456.78 1456.78
enclosure
L.T. XLPE Amourred 2 Core
Mtr 40 52.00 2080.00
16 Sqmm cable
Meter Board No 1 74.20 74.20
Three Phase Four Pole MCB
No 1 2096.00 2096.00
32A with enclosure
Reel Insulator 25mm No 30 2.12 63.60
G.I. Wire 8SWG Kg 5 57.40 287.00
G.I. Pipe 110 mm Mtr 3 238.00 714.00
G.I. Bend 110mm No 3 60.00 180.00
G.I. Flexible pipe 110mm Mtr. 2 106.00 212.00
G.I. coupling 110mm No 2 40.00 80.00
Sundries (Nut Bolts for
Earthing Point and fitting,
screws, Washers, drilling bit, No 1 400.00 400.00
Nails, Saddle clamps, lugs,
PVC RAWAL Plugs etc.)
Total 7,643.58
Approx. Labour Charges 15.00% 1,146.54
Transportation Charges 5.00% 382.18
Tools & Plants 1.50% 114.65
Contingencies 2.50% 191.09
Insurance & Finance Cost 1.50% 114.65
Grand Total 9592.69
Less Meter Cost 1456.78
Proposed Charges 8130.00
Table 10-4: Service connection charges for overhead connection (LT 3 Ph) for motive power
(>27 HP but <107 HP) or other (>20 kW but <80 kW) as proposed by MSEDCL
Table 10-5: Service connection charges for overhead (LT 3 Ph) for motive power (> 107 HP
but < 201 HP) or other (> 80 kW but <150 kW) as proposed by MSEDCL
HT supply
10.2.6 The Commission notes that MSEDCL has re-classified the connections in terms of load
limits and voltage level. It has provided the item-wise cost break up for its proposed service
connection charges for new overhead HT connections. MSEDCL submitted details as
below.
Table 10-6: Service connection charges for overhead connection (HT) 11 kV supply up to
1000 kVA as proposed by MSEDCL
Table 10-8 : Service connection charges for Overhead 22kV HT supply up to 1000 kVA as
proposed by MSEDCL
Table 10-9: Service connection charges for Overhead 22kV HT above 1000 kVA up to 10000
kVA as proposed by MSEDCL
Table 10-10 : Service connection charges for Overhead 33kV HT up to 20000 kVA as
proposed by MSEDCL
EHV Supply
10.2.7 MSEDCL has proposed charges for EHV supply and beyond SOP cases at actual.
10.2.8 The service connection charges for new underground connections as proposed by MSEDCL
are reproduced below.
MERC Order – Case No. 322 of 2019 Page 618 of 752
MYT Order of MSEDCL – True-up for FY 2017-18 and FY 2018-19, Provisional True-up of FY 2019-20 and Projection
of ARR for FY 2020-21 to FY 2024-25
LT supply
Single phase:
Table 10-11 : Service connection charges for underground connection (LT 1 Ph) for load up
to 5 kW as proposed by MSEDCL
Three phase:
Table 10-13: Service connection charges for underground connection (LT 3 Ph) motive
power (< 27 HP) or other (<20 kW) as proposed by MSEDCL
Table 10-14: Service connection charges for underground (LT 3 Ph) motive power (>27 HP
but <67 HP) or other (>20 kW but <50 kW) as proposed by MSEDCL
Table 10-15: Service connection charges for underground (LT 3 Ph) motive power (> 67 HP
but <134 HP) or other (> 50 kW but <100 kW) as proposed by MSEDCL
Table 10-16: Service connection charges for underground (LT 3 Ph) motive power (>
134 HP but <201 HP) or other (> 100 kW but < 150 kW) as proposed by MSEDCL
HT supply
10.2.9 The Commission observes that MSEDCL has re-classified the connections in terms of load
limits and voltage level. It has provided the item-wise cost break up for its proposed service
connection charges for new underground HT connections. MSEDCL submitted details as
below.
Table 10-17: Service connection charges for underground 11 kV HT supply up to 1000 kVA
as proposed by MSEDCL
Material Unit Quantity Rate in Rs. Cost in Rs
HT (11 kV) Metering
No. 1 85,000.00 85,000.00
Cubicle including CT & PT
HT TOD Meter 5A rating of
No 1 2,316.95 2,316.95
0.5s accuracy class
HT Earthing set (For
Set 9 547.00 4,923.00
cubical)
RSJ 152x152, 13 m long No 2 21,562.00 43,124.00
11 kV Pin Insulators with
No 3 135.00 405.00
G.I. Pins
Disc Insulator 11 KV 70 KN No 3 344.00 1,032.00
Strain Hardware for
Set 3 179.00 537.00
Weasel/Squirrel
11 kV Lightning Arrestor
(Gapless type) with Set 1 1,268.00 1,268.00
disconnector
11KV A.B. Switch, 400 A Set 1 9,240.00 9,240.00
Table 10-18: Service connection charges for underground 11 kV HT above 1000 kVA up to
5000 kVA as proposed by MSEDCL
Material Unit Quantity Rate in Rs. Cost in Rs
HT (11 kV) Metering
No. 1 85,000.00 85,000.00
Cubicle including CT & PT
HT TOD Meter 1A & 5A
rating of 0.2s accurancy No 1 5,709.00 5,709.00
class
HT Earthing set (For
Set 9 546.81 4,921.30
cubical)
RSJ 152x152, 13 m long No 2 21562.00 43,124.00
11 kV Pin Insulators with
No 3 135.00 405.00
G.I. Pins
Disc Insulator 11 KV 70 KN No 3 344.00 1,032.00
Strain Hardware for
Set 3 179.00 537.00
Weasel/Squirrel
11 kV Lightning Arrestor
(Gapless type) with Set 1 1,268.00 1,268.00
disconnector
11 KV Isolators with EB
Set 1 30,025.00 30,025.00
(800 A)
M.S. Flats (50 X 10mm) Kg 20 48.50 970.00
M.S. Channel 100x50x6
Kg 160 51.80 8,288.00
mm
M.S. Channel 75x40x6 mm Kg 150 51.80 7,770.00
M.S. angle 50x50x6 mm Kg 65 51.80 3,367.00
H.T. Stay Set No 2 546.81 1,093.62
Stay Wire 7/8 Kg 25 57.45 1,436.25
Earthing Sets H.T. No 5 302.32 1,511.61
1” PVC pipe for LA
Mtr. 16 73.00 1,168.00
earthing separation
G.I. Wire 8 SWG/ 6 SWG Kg 25 57.07 1,426.76
G.I. Barbed Wire 'A' type. Kg 3 57.88 173.63
Danger Board in yard. No 2 46.64 93.28
Red Oxide Paint for 2 coats Ltr 6 54.06 324.36
Aluminium Paint for 1 coat Ltr 4 93.28 373.12
Black Bituminus Paint Ltr 2 43.46 86.92
MERC Order – Case No. 322 of 2019 Page 624 of 752