Madhya Gujarat Vij Company Ltd.

BEFORE THE GUJARAT ELECTRICITY REGULATORY COMMISSION GANDHINAGAR Summary of Case No. 1761 /2018 In respect of Petition for True up of & Mid-Term Review of ARR for to & Tariff determination for Filed by:- Madhya Gujarat Vij Company Ltd. Corp. Office: Sardar Patel Vidyut Bhavan, Race Course Road, VADODARA 390 007 Save Energy for Benefit of Self and Nation Page 1 of 10

Summary of Petition No. 1761 / 2018 1. Introduction: Madhya Gujarat Vij Company Limited (MGVCL) is one of the distribution companies engaged in distribution of electricity in the Central Part of Gujarat. The Madhya Gujarat Vij Co. Ltd obtained its Certificate of Commencement of Business on the 15 th October, 2003. However, the Company started its commercial operations w.e.f. 1 st April 2005. The Gujarat Electricity Regulatory Commission (hereinafter referred to as GERC or the Hon ble Commission ), an independent statutory body constituted under the provisions of the Electricity Regulatory Commissions (ERC) Act, 1998, is vested with the authority of regulating the power sector in the State inter alia setting of tariff for electricity consumers. The Hon ble Commission is now deemed to be the Commission established under Sub-Section (1) of Section-3 of the Gujarat Electricity Industries (Reorganization and Regulations) Act, 2003. Hon ble Commission notified the Gujarat Electricity Regulatory Commission (Multi- Year Tariff) Regulations, 2016 ( GERC MYT Regulations, 2016 ) on 29th March 2016 and shall be applicable for determination of tariff in all cases covered under the regulations from 1st April, 2016 onwards. Under section 62 of the Electricity Act, 2003 and under the MYT Regulation, 2016 along with other guidelines and directions issued by the GERC from time to time, MGVCL is required to file a Petition for Truing-Up for and Midterm Review of ARR for to and Determination of final Tariff for to the Hon ble Commission: Submission by MGVCL to the Hon ble Commission Under section 62 of the Electricity Act, 2003 and GERC MYT Regulations, 2016, MGVCL has submitted the Petition for Truing-Up for and Midterm Review of ARR for to and Determination of final Tariff for to the Hon ble Commission for approval. (2) True Up for : (a) Category wise Sales and Revenue for : A LT Consumers Sales(MUs) (Actual) 1 RGP 2,636 2,475 2 GLP 66 60 3 Non-RGP & LTMD 1,485 1,465 4 Public Water Works 263 286 5 Agriculture - Metered 472 753 6 Agriculture - Unmetered 950 475 7 Public Lighting 64 63 LT Total (A) 5,936 5,577 B HT Consumers 8 Industrial HT 3,436 3,703 9 Railway Traction - - HT Total (A) 3,436 3,703 Grand Total (A + B) 9,372 9,281 Page 2 of 10

(b) Distribution loss for : (Actual) 1 Distribution Losses 11.70% 10.63% (c) Energy Requirement: The gross energy requirement for MGVCL is as follows (Actual vis-à-vis approved) Energy Requirement and Energy Balance Unit (Actual) Energy Sales MUs 9,372 9,281 Distribution Losses MUs 1,242 1,104 % 11.70% 10.63% Energy Requirement MUs 10,614 10,385 Local Power Purchase by Discom MUs - 60 Power Purchase at T<>D periphery from GUVNL MUs 10,614 10,325 Transmission Losses MUs 425 402 % 3.85% 3.75% Total Energy to be input to Transmission System MUs 11,039 10,727 Pooled Losses in PGCIL System MUs 213 233 Total Energy Requirement ( 7 + 8 + 4) MUs 11,252 11,020 Capital Expenditure incurred by MGVCL in vis-à-vis approved is as under: Schemes (Actual) Deviation A Distribution Schemes Normal Development Scheme 22.85 35.41 (12.56) Distribution Infra & Shifting Schemes(DISS) 22.85 19.93 2.92 Electrification of hutments 8.80 10.58 (1.78) Kutir Jyoti Scheme 2.57 2.63 (0.06) Others Harijan Basti Petapara 0.80 0.60 0.20 Total 57.87 69.15 (11.28) B Rural Electrification Schemes - Plan TASP(Wells & Petapara) 127.47 84.06 43.41 Special Component plan 4.17 1.75 2.42 RE Wells(OA +SPA) 163.95 66.70 97.25 Dark Zone 63.24 12.10 51.14 Total 358.83 164.61 194.22 C Central Government Scheme - Plan Integrated Power Development Scheme (IPDS) 100.00 94.88 5.12 Din Dayal Upadhyay Gramin Jyoti Yojana (DDUGJY) 70.00 40.04 29.96 R-APDRP(Scada)-A 8.00 10.02 (2.02) R-APDRP(Scada)-B 2.00-2.00 RAPDRP (Part A) - - - RAPDRP (Part B) 8.00 1.46 6.54 Total 188.00 146.40 41.60 D Other New Schemes Sagar Khedu 1.50 1.53 (0.03) Energy Conservation(HVDS) 5.00 5.41 (0.41) Vehicle 0.86 0.80 0.06 Sardar Krushi Jyoti Yojna - 3.06 (3.06) Misc Civil + Electrical Works + Furniture 4.80 6.72 (1.92) Total 12.16 17.51 (5.35) F Capital Expenditure Total 616.86 397.67 219.19 Funding of CAPEX: The detailed breakup of funding of capital expenditure during is mentioned below. (Actual) Deviation 1 Capitalization 616.86 401.08 215.78 2 Less : Consumer Contribution 22.85 99.67 (76.82) 3 Grants 120.67 202.69 (82.02) 4 Balance CAPEX 473.34 98.73 374.61 5 Debt @ 70% 331.34 69.11 262.23 6 Equity @ 30% 142.00 29.62 112.38 Page 3 of 10

(d) Aggregate Revenue Requirement of : Aggregate Revenue Requirement for for MGVCL in comparison with values approved by the Hon ble Commission is as under. (Actual) Deviation 1 Cost of Power Purchase 5,007.00 4,703.89 303.11 2 Operation & Maintenance Expenses 404.67 564.34 (159.67) 2.1 Employee Cost 374.82 478.30 (103.48) 2.2 Repair & Maintenance 56.60 59.00 (2.40) 2.3 Administration & General Charges 70.21 74.48 (4.27) 2.4 Other Debits - - - 2.5 Extraordinary Items - - - 2.6 Net Prior Period Expenses / (Income) - - - 2.7 Other Expenses Capitalised (96.96) (47.44) (49.52) 3 Depreciation 276.49 241.48 35.01 4 Interest & Finance Charges 102.86 68.37 34.49 5 Interest on Working Capital - - - 6 Provision for Bad Debts - 0.00 (0.00) 7 Sub-Total [1 to 6] 5,791.02 5,578.07 212.95 8 Return on Equity 147.50 132.75 14.75 9 Provision for Tax / Tax Paid 17.59 12.11 5.48 10 Total Expenditure (7 to 9) 5,956.11 5,722.93 233.18 11 Less: Non-Tariff Income 137.11 130.28 6.83 12 Aggregate Revenue Requirement (10-11) 5,819.00 5,592.65 226.35 (e) Net Gain/ (Loss): Net Gain/Loss to MGVCL on account of controllable factors and uncontrollable factors is given here under. (Actual) Gain/(Loss) due to Controllable Factors Gain/(Loss) due to Uncontrollable Factors 1 Cost of Power Purchase 5,007.00 4,703.89 53.72 249.39 2 Operation & Maintenance Expenses 404.67 564.34 (83.00) (76.67) 2.1 Employee Cost 374.82 478.30 (76.34) (27.14) 2.2 Repair & Maintenance 56.60 59.00 (2.40) - 2.3 Administration & General Charges 70.21 74.48 (4.27) - 2.4 Other Debits - - - - 2.5 Extraordinary Items - - - - 2.6 Net Prior Period Expenses / (Income) - - - - 2.7 Other Expenses Capitalised (96.96) (47.44) - (49.52) 3 Depreciation 276.49 241.48-35.01 4 Interest & Finance Charges 102.86 68.37-34.49 5 Interest on Working Capital - - - - 6 Provision for Bad Debts - 0.00 (0.00) - 7 Return on Equity 147.50 132.75-14.75 8 Provision for Tax / Tax Paid 17.59 12.11-5.48 9 ARR (1 to 8) 5,956.11 5,722.93 (29.29) 262.46 10 Non - Tariff Income 137.11 130.28-6.83 11 Total ARR (9-10) 5,819.00 5,592.65 (29.29) 255.63 (f) Revenue for : Actual Revenue of MGVCL vis-à-vis approved for. Page 4 of 10

(Actual) 1 Revenue from Sale of Power 4,284.36 2 Revenue from FPPPA at Rs. 1.43 per kwh 1,340.13 5,284.25 3 Other Income (Consumer related) 102.45 156.15 4 Total Revenue excluding subsidy (1 + 2 + 3) 5,726.94 5,440.40 5 Agriculture Subsidy 74.25 73.81 6 Total Revenue including subsidy (4 + 5) 5,801.19 5,514.21 Revenue Gap for FY 2015-16:The Hon ble Commission in its Order dated 31st March, 2017 has approved Aggregate Revenue Requirement of Rs. 5819.00 Crores for. The Hon ble Commission had also added Revenue gap/(surplus) of Rs. (159.70) Crores due to truing up of FY 2015-16 in the above Aggregate Revenue Requirement. As per the mechanism specified in the MYT Regulation 2016, MGVCL proposes to pass on a sum of 1/3rd of total gain/(loss) on account of controllable factors i.e. Rs. (9.76) Crores and total gain/(loss) on account of uncontrollable factors i.e. Rs.255.63 Crores to the consumers. Adjusting these to the net Aggregate Revenue Requirement, MGVCL has arrived at the Revised Aggregate Revenue Requirement for at Rs. 5413.43 Crores. This revised Aggregate Revenue Requirement is compared against the revised income under various heads including Revenue with Existing Tariff of Rs. 5,284.25 Crores, Other Consumer related Income of Rs. 156.15 Crores, Agriculture Subsidies of Rs. 73.81Crores and GUVNL profit allocation of Rs. 16.18 Crore, summing up to a Total Revenue of Rs. 5,530.39 Crores. Accordingly, total Revenue Gap / (Surplus) of MGVCL for after treatment of gain/(loss) due to controllable / uncontrollable factors is computed at Rs. (116.96) Crores as shown in the table below: (Actual) 1 Aggregate Revenue Requirement originally approved for 5,819.00 2 Add: Gap/(Surplus) of FY 2015-16 (159.70) 3 Gain / (Loss) on account of Uncontrollable factor to be passed on to Consumer 255.63 4 Gain / (Loss) on account of Controllable factor to be passed on to Consumer (1/3rd of Total Gain / Loss) (9.76) 5 Revised ARR for (1 + 2-3 - 4) 5,413.43 6 Revenue from Sale of Power 5,284.25 7 Other Income (Consumer related) 156.15 8 Total Revenue excluding Subsidy (6 + 7) 5,440.40 9 Agriculture Subsidy 73.81 10 GUVNL Profit / (Loss) Allocation 16.18 11 Total Revenue including Subsidy (8 + 9 + 10) 5,530.39 12 Revised Gap after treating gains/(losses) due to Controllable/ Uncontrollable factors (5-11) (116.96) The Hon ble Commission is requested to approve above mentioned gap and allow MGVCL to recover this gap in. Page 5 of 10

(4) MID-TERM REVIEW OF TO (a) Projection of Energy Requirement for to Approach for Sales Projection It has been observed from past experience that the historical trend method has proved to be a reasonably accurate and well accepted method for estimating the load, number of consumers and energy consumption. In light of the above, MGVCL has estimated the above for various customer categories primarily based on the CAGR trends during past years. Wherever the trend has seemed unreasonable or unsustainable, the growth factors have been corrected by the company, to arrive at more realistic projections. Summary of Growth & Projections The growth rates observed in the energy sold to each consumer category has been analysed for the purpose of sales projections for to 2020-21. The analysis of the growth rate lends insight into the behaviour of each category and hence forms the basis of forecasting the sales for each category. The Break-up of the past sales and the CAGR growth rates for different periods (5 years, 4 year, 3 year, 2 year and year on year) thereof are as follows. CAGR has been computed for each consumer category for the past 5-year period FY 2012-13 to, the 4-year period FY 2013-14 to, the 3-year period FY 2014-15 to, and the 2-year period FY 2015-16 to, along with the y-o-y growth rate of FY 2016-17 over, as summarized in the table below: Following table summarizes the growth rate assumptions Category Sales Consumers Connected Load LOW TENSION 1 RGP 6.37% 1.95% 5.75% 2 GLP 4.92% 4.66% 10.44% 3 Non-RGP & LTMD 5.43% 3.52% 6.60% 4 Public Water Works 12.74% 10.54% 13.01% 5 Agriculture-Unmetered 0.00% 0.00% 0.00% 6 Agriculture-Metered 0.00% 0.00% 0.00% 7 Street Light 0.54% 4.81% 0.00% HIGH TENSION 1 Industrial HT 5.42% 5.89% 8.22% 2 Railway Traction 0.00% 0.00% 0.00% The estimated Sales, No. of consumers and Connected load based on the above growth rates and as per the methodology used for agriculture metered category are projected in the table below: PROJECTION OF SALES (MUS) Category LOW TENSION 1 RGP 2,801 2,979 2 GLP 66 70 3 Non-RGP & LTMD 1,628 1,716 4 Public Water Works 363 409 5 Agriculture-Unmetered 475 475 6 Agriculture-Metered 933 1,023 7 Street Light 63 64 Sub-Total 6,330 6,736 HIGH TENSION 1 Industrial HT - - 2 Railway Traction 4,116 4,339 Sub Total 4,116 4,339 TOTAL 10,446 11,076 Page 6 of 10

PROJECTION OF NO. OF CONSUMERS Category LOW TENSION 1 RGP 2,659,200 2,710,943 2 GLP 26,248 27,471 3 Non-RGP & LTMD 325,248 336,682 4 Public Water Works 24,978 27,611 5 Agriculture-Unmetered 26,145 26,145 6 Agriculture-Metered 158,788 174,428 7 Street Light 8,523 8,933 Sub-Total 3,229,130 3,312,213 HIGH TENSION 1 Industrial HT 2,318 2,454 2 Railway Traction - - Sub Total 2,318 2,454 TOTAL 3,231,447 3,314,667 PROJECTION OF CONNECTED LOAD (MW/MVA) Category LOW TENSION 1 RGP 2,877 3,043 2 GLP 85 94 3 Non-RGP & LTMD 1,567 1,670 4 Public Water Works 199 224 5 Agriculture-Unmetered 209 209 6 Agriculture-Metered 1,019 1,123 7 Street Light 24 24 Sub-Total 5,978 6,386 HIGH TENSION 1 Industrial HT 1,640 1,775 2 Railway Traction - - Sub Total 1,640 1,775 TOTAL 7,618 8,161 (b) Projection of Distribution Loss and Energy Requirement: Distribution Loss for the to 2020-21 Distribution Loss 11.60% 11.60% 11.55% 11.55% (c) Energy Requirement for the to 2020-21: Energy Balance for the to 2020-21 S.No. Unit 1 Energy Sales MUs 10,452.00 10,446.10 11,032.00 11,075.83 MUs 1,371.53 1,370.76 1,440.58 1,446.31 2 Distribution Losses % 11.60% 11.60% 11.55% 11.55% 3 Energy Requirement MUs 11,823.53 11,816.86 12,472.58 12,522.14 MUs 473.00 473.00 499.00 501.00 4 Transmission Losses % 3.85% 3.85% 3.85% 3.85% 5 Total Energy to be input to Transmission System MUs 12,296.53 12,289.86 12,971.58 13,023.14 6 Pooled Losses in PGCIL System MUs 213.00 232.83 213.00 232.83 7 Total Energy Requirement MUs 12,509.53 12,522.69 13,184.58 13,255.97 (d) Power Purchase Cost: Bulk Supply Tariff: For estimation of Power Purchase Cost methodology of Bulk Supply Tariff (BST) is proposed with the objective of keeping uniform retail tariff throughout the State. The BST for DISCOMs includes the cost of power purchase from various generating stations, the transmission costs of PGCIL, GETCO and the cost of bulk supplier GUVNL. The revenue earned from sale of traded power is subtracted from the total power purchase cost to arrive at net power purchase cost to be charged to the four DISCOMs. The amount available for power purchase with the four DISCOMs is arrived at by subtracting the sum of total expenses other than the power purchase cost of all the four DISCOMs from the total revenue of the four DISCOMs. The difference between the net power purchase cost and the amount available with the Page 7 of 10

four Discoms, indicates the revenue gap. This revenue gap varies from Discom to Discom. The bulk supply tariffs for the four Discoms are fixed keeping in view the magnitude of the revenue gap. For the, total gap projected is Rs.1677 Crores for the sector as a whole, for MGVCL, the proportionate allocated gap for FY 2019-20 works out to be Rs. 211 Crores. The allocated gap amount of each DISCOM has been added to the amount available for power purchase for that DISCOM and the figure has been divided by the number of units projected to be purchased by the DISCOMs to arrive at BST at Rs/kWh. Accordingly BST for MGVCL for works out to Rs. 4.44 per kwh and total Power Purchase Cost of Rs. 5565 Crores, and for Rs. 4.26 per kwh and total power purchase cost Rs. 5652 Crores. (e) Capital Expenditure Plan: The scheme-wise approved and projected capital expenditure for to is as shown below: A Distribution Schemes Normal Development Scheme 30.38 30.38 31.94 31.94 Distribution Infra & Shifting Schemes(DISS) 30.38 20.00 31.94 20.00 Electrification of hutments 11.70 5.66 12.30 5.25 Kutir Jyoti Scheme 3.42 2.40 3.50 2.10 Others Harijan Basti Petapara 1.06 0.30 1.12 0.30 Total 76.94 58.74 80.80 59.59 B Rural Electrification Schemes - Plan TASP(Wells & Petapara) 169.46 51.75 178.18 55.00 Special Component plan 5.54 1.25 5.83 1.25 RE Wells(OA +SPA) 217.95 87.15 229.18 77.00 Dark Zone 84.07 13.00 88.40 9.25 Total 477.02 153.15 501.59 142.50 C Central Government Scheme - Plan Integrated Power Development Scheme (IPDS) - 22.50 - - Din Dayal Upadhyay Gramin Jyoti Yojana (DDUGJY) - 15.60 - - R-APDRP(Scada)-A - 2.00-0.87 PSDF - 14.00-14.12 Total - 54.10-14.99 D Other New Schemes Sagar Khedu 1.50 1.50 1.50 1.50 Energy Conservation(HVDS) 5.00 5.00 5.00 5.00 Vehicle 1.14 1.14 1.20 1.20 Misc Civil + Electrical Works 3.20 3.20 2.00 2.00 Sardar Krushi Jyoti Yojna - 3.66-3.66 Total 10.84 14.50 9.70 13.36 F Capital Expenditure Total 564.80 280.49 592.09 230.44 (f) Funding of CAPEX: Funding of above mentioned CAPEX is envisaged through various sources categorized indebt four headings namely: Consumer Contribution, Grants, Equity and Debt. 1 Capitalisation 564.79 280.49 592.09 230.44 2 Less : Consumer Contribution 30.38 30.38 31.94 31.94 3 Grants 22.68 22.68 23.42 23.42 4 Balance CAPEX 511.73 227.43 536.73 175.08 5 Debt @ 70% 358.21 159.20 375.71 122.56 6 Equity @ 30% 153.52 68.23 161.02 52.52 (g) Summary of ARR projected for to 2020-21 : Table below shows projection of Aggregate Revenue Requirement by MGVCL for the control period to 2020-21. Page 8 of 10

1 Cost of Power Purchase 5,654.98 5,564.66 6,145.38 5,652.02 2 Operation & Maintenance Expenses 452.29 748.40 478.16 839.04 2.1 Employee Cost 418.93 659.69 442.89 745.26 2.2 Repair & Maintenance 63.26 63.26 66.87 66.87 2.3 Administration & General Charges 78.47 78.47 82.96 82.96 2.4 Other Debits - - - - 2.5 Extraordinary Items - - - - 2.6 Net Prior Period Expenses / (Income) - - - - 2.7 Other Expenses Capitalised (108.37) (53.02) (114.57) (56.05) 3 Depreciation 329.79 263.18 360.01 270.64 4 Interest & Finance Charges 124.83 71.64 134.07 76.12 5 Interest on Working Capital - - - - 6 Provision for Bad Debts - 0.00-0.00 7 Sub-Total [1 to 6] 6,561.89 6,647.88 7,117.62 6,837.82 8 Return on Equity 190.03 149.67 212.05 158.12 9 Provision for Tax / Tax Paid 17.59 12.11 17.59 12.11 10 Total Expenditure (7 to 9) 6,769.51 6,809.66 7,347.26 7,008.05 11 Less: Non-Tariff Income 137.11 130.28 137.11 130.28 12 Aggregate Revenue Requirement (10-11) 6,632.40 6,679.38 7,210.15 6,877.77 MGVCL request the Hon ble Commission to approve the above mentioned Aggregate Revenue Requirement for to 2020-21. (5) Tariff for FY 2019-20: Estimated Revenue at existing Tariff for and estimated revenue gap at Existing tariff for Total Revenue for at existing Tariff: 1 Revenue with Existing Tariff 4,461.61 2 FPPPA Charges 1,702.72 3 Other Income (Consumer related) 109.47 4 Agriculture Subsidy 77.89 5 Total Revenue including subsidy (1 to 4) 6,351.69 Estimated Revenue Gap for at Existing Tariff 1 Aggregate Revenue Requirement 6,679.38 2 Revenue Gap from True up of (116.96) 3 Total Aggregate Revenue Requirement 6,562.42 4 Revenue with Existing Tariff 4,461.61 5 FPPPA Charges 1,702.72 6 Other Income (Consumer related) 109.47 7 Agriculture Subsidy 77.89 8 Total Revenue including subsidy (4 to 7) 6,351.69 9 Gap / (Surplus) (3-8) 210.73 The Hon ble Commission is requested to approve the above mentioned gap. There are no changes/revision/ proposed in the tariff structure by the company for Page 9 of 10

(6) Prayer MGVCL respectfully prays to the Hon'ble Commission: 1. To admit this Petition seeking True up of, Mid-term Review of ARR for to and Determination of Tariff for. 2. To approve the True up for and allow sharing of gains/losses with the Consumers as per sharing mechanism prescribed in the GERC MYT Regulations, 2016. 3. To approve Mid-term Review of ARR for to as per GERC MYT Regulations 2016. 4. To consider approved True up parameters & Multi-Year ARR of GSECL, GETCO and SLDC while finalizing Tariff of the Petitioner. 5. To approve the terms and conditions of Tariff for and various other matters as proposed in this petition and proposed changes therein. 6. Pass suitable orders for implementation of Tariff Proposal for for making it applicable from 1st April, 2019 onwards. 7. To grant any other relief as the Hon'ble Commission may consider appropriate. 8. The Petitioner craves leave of the Hon'ble Commission to allow further submissions, addition and alteration to this Petition as may be necessary from time to time. 9. Pass any other Order as the Hon ble Commission may deem fit and appropriate under the circumstances of the case and in the interest of justice. (7) Provisions for availing the petition copy : Copy of the petition will be available for inspection as well as for sale at the cost of Rs. 250/- to the interested persons at the office of The Chief Engineer, Corporate Office, Madhya Gujarat Vij Company Ltd, S.P.Vidyut Bhavan,Race Course,vadodara-390 007 and at the office of the Superintending Engineer of MGVCL, in Charge of O&M Circle. For obtaining the copy of the petition by post, postage fee @ Rs.50/- will be payable extra. NOTE: - The total amount in such event is to be sent by Demand Draft payable in favor of Madhya Gujarat Vij Company Ltd. The electronic copies of the above mentioned petition are available at website www.guvnl.com and www.mgvcl.com (8) Guideline for submission of response: In accordance with GERC ( Conduct of Business) Regulations 2004, it is hereby notified that the persons who are interested in filing their objections/suggestions on the above subject matter petition, may file the same with the Secretary, Gujarat Electricity Regulatory Commission, 6 th floor, GIFT One, Road 5C,Zone 5, GIFT City, Gandhinagar 382 355 along with the document on which they want to rely upon, in five sets, duly supported by an affidavit with the copy to the undersigned on or before 07.01.2019 and also indicate whether they intend to be heard in person. Page 10 of 10