BEFORE THE HIMACHAL PRADESH ELECTRICITY REGULATORY COMMISSION, SHIMLA

Transcription

1 BEFORE THE HIMACHAL PRADESH ELECTRICITY REGULATORY COMMISSION, SHIMLA M.A. No Case No 176/2012 IN THE MAlTER OF: IN THE MAlTER OF Determination of Averap Pooled Purchase Cost (APpe) for FY AND Himachal Pradesh State Electricity Board Umlted (hereinafter referred to as "HPSEBL" or "The HPSEBLIf), Vidyut Bhawan, Shlmla INDEX Sr. No. Description Page No. 1. Petition Affidavit 16

2 -----~ BEFORE THE HIMACHAL PRADESH ELECTRICITY REGULATORY COMMISSION, SHIMLA Determination ofaverage Pooled Purchase Cost for FY Submitted to Himachal Pradesh State Electric~ty Regulatory Commission Himachal Pradesh State Electricity Board Limited Vidyut Bhawan, Shimla (H.P.) HPSEB Limited i April20J2

3 ~- BEFORE TIlE HIMACHAL PRADESH ELECTRICITY REGULATORY COMMISSION, SHIMLA M.A. No Case No 17fV2012 IN THE MAITER OF: Determination of Average Pooled. Purchase Cost (APPC) forfy AND IN THE MAITER OF Himachal Pradesh State Electricity Board Limited (hereinafter referred. to as "HPSEBL" or "The HPSEBL"), Vidyut Bhawan, Shimla Applicant The Applicant respectfully submits as under: 1. Himachal Pradesh State Electricity Board Limited (HPSEBL) is Ii deemed licensee under first proviso. of Section 14 of the Electricity Act 2003 for distribution and supply of electricity in the state of Himach8I Pradesh. Consequent to the enactment of the Electricity Act, 2003 (hereinafter referred to as the "Act"), the process of approval of proposed tariffs is vested with the State Commission. Based on the provisions of Section 62 of the Act and in compliance with the directives of the Commission on the matter, HPSEBL is filing the current petition, in order to meet its financial requirements. 2. This Petition indicates the review of methodology of determination of APPC for FY LCCotM,"" B.I.td., Vldyut Sh... t710m HPSEB Limited ii

4 AI:. Table ofcontents BACKGROUND..._...4 A2: DETERMINATION OF APPC RATE FOR FY DEFlNrnO}'IJ... :... 5 ExIs'In<lG MlrmODOLOGY... 5 RA110}'IJALE FOR PROPOSED R.EvISIO}'IJ I!'IJ APPROVED MElHODOLOGY... 6 PROPOSAL FOR APPC RATE FOR FY A3: PRAyER... " List OfTables TABLE 1: BANIaNG DIl'rAILS... _ TABLE 2: APPC RATES... _... _ HPSEB Limited iii

5 DETERMINATION OF APPC FOR FY AI: BACKGROUND 1.1 HPSEB Limited likes to submit that while nearly all the components of power purchase cost is determined by CERC &: HPERC in advance, the Average Pooled Power Purchase Rate (APPC Rate) is being determined by HPERC on year to year basis. 1.2 HPSEB Limited thus submits its current petition for determination of APPC rates which covers the following: (1) Review of Methodology for Determination of Average Pooled Power Purchase Rate (APPC Rates). (2) Proposal for APPC Rate for FY HPSEB Limited Page 4

6 DETERMINATION OF APPC FOR FY A2: DETERMINATION OF APPC RATE FOR FY As per CERC Terms and Conditions for recognition and issuance of Renewable Energy Certificate for Renewable Energy Generation Regulations, 2010, Pooled Cost of Power Purchase Cost means: The weighted average pooled price at which the Distribution Licensee has putchased the electricity including cost 0/ self generation, if any, in the previous year from all the energy suppliers, long-term and short-term, but excluding those based on renewable energy sources, as the case may be. 2.2 Thus the definition focuses on the following: (1) The Purchase ofelectricity should be from all energy suppliers, (i) (ii) (iii) (iv) which includes long term suppliers which includes short term suppliers which includes own generation which excludes renewable energy sources (2) The Purchase of.electricity should be in the previous year only which in this case is FY 2012:..13, Existing Methodology 2.3 While approving the Average Pooled Power Purchase Cost for FY , the Commission had stated the following: Total power purchased is disposed ofji utilized by way of sale, within and outside State and by way ofbanking. Power purchase only is relevant for APPC and disposav j. utilization ofpower is not relevant to the context ofdetermination ofappc. Banking has three componen~ rr tfip"'/:...(c0fii""" pi..',~ :",!,l<:',waft, "'~ vi" """.,.. ".. ~~ HPSEB Limited Page 5

7 (i) (ii) (iii) certain quantum ofenergy out ()f total purchases is banked during the year and the same quantum is received back dunng tire same year is called contra banking; certain quantum of energy is borrowed from other Discoms during the year which is to be returned in the subsequent year is known as forward banking under purchase category and quantum sold during tire year under forward banking will be received back in the next financial year is called return banking under purchase category. Where tire outward banking (banking sale) is from out ofpower purchased during tire year from energy supplier (long term and short term), its cost is already paid. Therefore, if the same quantum is received as inward banking (contra banking purchase),.such quantum and price should not be included over and above tire quantum or price already taken into account, out of which such power has been banked. The above figures indicate that out of the total inward banking (banking purchase) of MU, only MU is contra banking for It is true that Commission had taken cost of banking power, whether purchase or sale, as zero because in the absence offirm cost ofsuch power any notional cost leads to distorted results in profit!loss in the balance sheet. It is also true that banking a"angement as a practice in tire State is rollinga"angement involving contra, /onoard and return banking which is with various Discoms in the region. For the purpose ofappc only the weighted pooled price. of previous year is required to be taken into account, therefore, the Commission is of the view that against the total banking purchase of MU, only MU is contra and this quantum shall not be counted in the total power purchase quantum during the year. However, MU has been received as inward banking during tire year over and above quantum taken into account as purchasedfrom tire energy supplier, tlrerefore, this is an additional power purchase. Since there is no criteria for determination ofrate and as a prudent practice tire Commission had taken such banking sale and purchase at zero mst, this quantum ofenergy shall be treated as additional purchase at zero cost. Rationale for Proposed Revision in Approved Methodology 2.4 The Hon'ble Commission in previous APPC Order had considered only the forward banking purchase. However, HPSEB Umited would request the Commission to review the methodology for consideration of various J. components of Banking Power. In view of the above, HPSEB Limited likes to I.[' submit the following:.... CCOllW ltd. Vldyut 81' W HPSEB Limited Page 6

8 ~ DEmRMINATION Of' APPe POR f'y M The definition focuses onthe following: (1) The Purchase ofelectricity should befrom all energy suppliers, (i) (ii) (iii) (iv) which includes long term suppliers which includes short term suppliers which includes own generation which excludes renewable energy sources HME -_. ~ (2) The Purchase of Electricity should be in the previous year only which in this CilSe is FY , (3) The sale component has no impact whatsoever on the determination ofappc and ~ce should be kept out ofpreview ofdetermination ofappc, even ifit is banking sale., 26 The Commission had not considered the contra banking and had only considered the inward banking for the purpose of detennination of APPC. 2.7 However, it Is again submitted that Banking Purchase by any means i.e. forward! contra! returned during the Financial Year is definitely a source of Power to meet up the deficit during the winter months. Had the banking arrangement not present, additional purchase would have to be done from the Market! Power Exchange to meet 'up this deficit which is evident from the example below: In Summer In Winter Purchase fromppa6: Alloations SOOMU Purchase from PPA 6: Allocations SOOMU Net Sale within State 350MU Net Sale within State 600MU Power Available for f/fj Sale 150MU Power Purchased fromjls l00mu Options Available for JIS Sale 1. Banking Sale 2. Bilateral Sale 3. Sale at Power Exchange Options Available for JIS Purchase 1. Banking Purchase 2. Bilateral purchase 3. Purchase from Exchangl'! Power Options Exercised MU Contra Banking MU Forward Banking MU PX Sale Options Exercised MU Contra Banking MU Forward Banking ~9 I~.. ;~-: ::~~-i-ud p-ag-e--7 '71~ A~pr_il_2_0 13 I

9 -~ DETERMINATION OF APPC FOR FY It is evident from above that the Net Purchase of Power from all sources in the FY is 1100 MU as pet: fojiowing details: a) 500 MU in Summer from Regular Sources. b) 500 MU in Winter from Regular Sources. c) 50 MU in Winter from Forward Banking. d) 50 MU in Winter from Contra Banking. 2.8 In case of HPSEB Limited, instead of considering the option of sale of surplus power in summer in open market and market purchase of power in winter, option of banking sale of power in summer months and banking purchase of power in winter months is opted as alternative source of power and this factor needs to be considered by the Hon'ble Commission. 2.9 It is also submitted that the Banking is agreemented purchase of power on short term basis Regarding the. pricing of Banking Power following factors needs to be considered. (1) Since the Commission considers the availability of power from banking at "Zero Cost" while approving the Power Purchase Cost in various tarifforders and true-up orders, the HPSEB Limited has also consi4ered the banking power at "Zero Cost" fot determination ofappc as banking cost is not a pass through in approved Power Purchase Cost. (2) It is further submitted that rationale for al'fjtovin~ considering the cost for banking should be uniform across all the orders issued by Hon'ble Commission so as to avoid ambiguity at any stage. (3) TlVhile banking of certain quantum of already purchased power, HPSEB Limited bears the loss of the "Opportunity Cost" ofthis power. The opportunity cost is the revenue that the HPSEB Limited would have earned had it had sold the power in the open market in that particular year and not resorted to Banking ofsame for the benefit ofthe consumers ofstate. (4) As HPSEB Limited Iuul already borne the loss of op1'ortunity cost while banking, it should not be burdened twice by non-consideration ofsame while ~ determininrappc and other re14ted costs...., fcoiim-e1ii B I!rl, Vi1yI.!! :::!'IWItft, HPSEB Limited Page 8

10 ~~ ~~ DETERMINATION OF APPC FOR FY types of banking purchase have been done by HPSEB Limited. Purchase Year Corresponding Retu""Sale Year Return Banking FY FY Contra Banking FY2012:..13 FY Forward Banking FY FY It is submitted that the Opportunity Cost of Returned Banking has already been borne by HPSEB Limited in the previous year. For exflmple, if 100 MU has been received in FY as the return banking for the forward banking done in previous year i.e. FY , the opportunity cost for same has been bome in FY only. Thus, the retuned banking cannot be considered as valid purchase for determination of APPC for FY as the definitiol\of APPC restricts the purchase cost to previous year only which in this case in FY However, for the Contra Banking during the year FY , HPSEB Limited had borne the loss of "Opportunity Cost" in same Financial Year for the interest of consumers of state and accordingly HPSEB Limited must get thebenefif/ due recognition of this loss and accordingly Contra Banking Purchase- must also be factored! considered for the de.termination of APPC for FY 2Oi3-14. : Further, the forward banking purchase have to be considered by the Hon'ble Commission while determining the APPC for FY as this is the additional purchase during the year to meet up the deficit in the winter In view of above, HPSEB Limited requests the Hon'ble Commission to kindly consider the following: (1) To consider.contra Bankingfor determination ofappc. (2) :fo consider Forward Bankingfor detenninahon ofappc. tlnmr (com~'" To consider all banking purchases at Zero Cost fordetenninahon ofappc. 8,Ltd., VldyUt sba,"",. 111'r16 Accordingly the Banking Purchase considered. for determination of APPC is tabulated below: HPSEB Limited Page 9

11 .~ ~~ DETERMINATION OF APPC FORFY Table 1: Banking Details Consideredfor. APPC SubTotal Consideredfor APPC Proposal for APPC Rate for FY Keeping in view of above, the free power rate is computed for FY considering factors mentioned below: (1) The actual prwehase (quantum and costs) for FY for 11 months (Aprl111'to Fimary 12) has been considered as details for March 12 is not yet a'dailable. (2) The arrears pertaining to past periods (paid in FY ) ha'de been excluded as these are not recurring in nature. (3) Unscheduled Interchange (UI) Purchase has also not been included in line with the philosophy appro'ded by the Hon'ble Commission in. ~ preoious year..., ngi".., (commerctiiit tine,ltd VkIyut Bh.~ The PGCIl/Transmission Charge$!' ULDC/ Other Charges in line with 1710CM. the philosophy appro'ded by the Hon'ble Commission in pre-oious year. HPSEB Limited. Page to

12 r ~ DETERMINAnON OF APPC FOR FY (5) The rates of Own generating stations have been taken from the MYT Orderfor 2fUI Control Period dated 19" July Table 2: APPC Rates Bassi Girl Bhaba BBMBOld BBMBNew Debar Pong Anta(LNG) ~ ;1'\(1''''''.Ltd 1110N Anta(G) Anta (L) Auraiya(LNG) Auraiya(G) HPSEB Limited Page 11

13 DETERMINATION OF APPC FOR f'y Dadri(LNG) Dadri(G) Dadri(L) Unchahar-I Unchahar-II Unchahar-ill Rihand-l SfPS Rihand-2 SfPS Rihand-3 SfPS Singrauli DadriIITPS Jhajjar SfPS Khalgaon Chamera-I Chamera-II Chamera-ill Salal Tanakpur Uri Dhauli Ganga Dulhasti ~ Sewa HPSEB Limited Page 12 Apri12013

14 PETERMINATIONOP APPCPORFY NAPP RAPP Nathpa Jhakri SeR Shanan ShananExtn Yamuna (U]VNL) Khara Baspa-ll Baspa II Sec Energy Tehri I ,79 Koteshwar Bai:ra Suil Chamera-I Chamera-ll Shanan Share Ranjeet Sagar Dam Malana- I Malana-ll Baspa -II Nathpa Jhakri Karcham Wangtoo (Upto5MW) (Above 5 MW) HPSEB Limited Page 13 ~~ "o't~~ ~\fi.. ~ (

15 DETERMINATION OF APPC FOR FY Baner Gaj Larji 71.31' KhauJi AD Hydro Chamera - III Budhil Banking o 0.00 Bilateral Purchase PXI/IEX I ',,I. : ~, : ~ In view of the above, while HPSEB limited has computed the APPC Rate with and without Free Power, it would like to request the Commission to kindly:. Approve the revised methodology for Determination of APPC Rate for ensuing and future years. I Approve the APPC Rate of 198 paise per unit for FY ! HPSBB Limited Page 14

16 ~ ~~ DETERMINATION OF APPC FOR FY A3: PRAYER 3.1 HPSEBL requests the Hon'ble Commission to: a) Approve the proposed methodology for computation of APPC Rate. b) Approve the APPC Rates as proposed. c) To tltake the APPC rates effective from 01 st. d) To condone any inadvertent omissions/ errors/ shortcomings and permit the Petitioner to add/ change/ modify/alter this filing and make further submissions as may be required at a future date e) To allow further submissions, addition and alteration to this Petition as may be necessitating from time to time. f) Treat the filing as complete in view of substantial compliance as also the specific requests for waivers with justification placed on record; g) And pass such other and further orders as are deemed fit and proper in the facts and circumstances of the case....,lfd., VkI;ut ~... t71.. HPSEB Limited Page 15

17 BEFORE THE HIMACHAL PRADESH ELECTRICITY REGULATORY COMMISSION, SHIMLA M.A. No Case No 176/2012 IN THE MATTER OF: Determination of Average Pooled Purchase Cost (APpe) for FY AND IN THE MATTER OF Himachal Prad~sh State' Electricity Board Umited (hereinafter rt!ferred to as "HPSEBL" or "The HPSEBLtI), Vldyut "~DJ,..~r8JIa.; ~ - Applicant ~--- * G) Name SUOIta Gupta T' \2., Area VisIt. Shiml;, oj' Affidavit in support of accompanying petitio...>., Reg No 36 l~~! Ok <:",{",, I, Er. Vog Raj, Son of late Shri Nidhu Ram, ~~bgii:i years, presently working as Chief Engineer (Commercial), HPSEBl Vi yut Bhawan, Shimla-4 do hereby solemnly affirm and declare that I am conversant with the facts of the case and that the contents of accompanying petition have been drafted at my instance and under my instructions, which have been read over and explained to me in vernacular and that the contents of the accompanying patition are true and correct to the best of my personal knowledge, as derived from the official record. i I further solemnly affrm and verify that this affidavit of mine is true; no part of it is false and nothing'material has been concealed there from. " ': ~ r,.,.,., NOTARY J.tl 2 APR 2Ul3 ShlmllDMfnat,,~.... ~~.'.:.-~,"-,r,. '"" J",,'"