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Distribution Companies in Andhra Pradesh, APEPCL and APSPDCL have filed petitions before the APERC for determination of Aggregate Revenue Requirement and tariffs for the year 2018-19. APERC, conducted public hearings  across the state as part of the tariff determination process and PEG submitted some comments and suggestions during the public hearing in Hyderabad. The presentation made at the hearing is available below.

The submission has taken a medium term perspective on the DISCOM operation and finances in order to highlight the infeasibility of sustaining current trends. The DISCOMs in their petitions have not asked for any tariff increase for the year 2018-19. However, they are also projecting a revenue gap of almost Rs.8000 crores, some of which might be met by state government subsidies. PEG has also highlighted the likelihood of the projected revenue gap being higher than that estimated by the DISCOMs which could also increase the burden of carrying cost. In its submission PEG has noted that there is possibility of underestimation of certain cost components and overestimation of some revenue heads.

Using Revenue and Tariff Analysis for Electric Utilities or RATE model, PEG has projected order of magnitude impacts for 2021-22 based on current trends. Even with current trends, costs increase significantly for the DISCOM and the increase is much more if 50% of the HT sales moves to open access or captive options or if 10 GW of RE capacity is added by 2022. Assuming a modest annual tariff increase of 1.7%, the cumulative revenue gap along with carrying cost for the two DISCOMs is estimated to be in the range of Rs.22,000 crores to Rs. 38,000 crores by 2021-22. In order to meet increasing costs, the tariffs need to increase at the rate of 10% to 19% per year. Alternatively, subsidies need to increase to meet the annual revenue gap such that the annual subsidy payment by 2021-22 is Rs.8,900 crores to Rs.13,600 crores.

The model results indicate that the current model is not sustainable for the state government or the power sector, and may lead to serious political and/or governance issues. Given the increasing cost competitiveness of alternate supply options, more and more cross subsiding consumers will migrate to open access, captive and rooftop solar options. At the same time, the average cost of supply for DISCOMs continues to increase.

The commission needs to take a comprehensive view of the impact of these changes on the sector and determine a transition plan for the DISCOM business model which addresses issue of the reducing room for cross subsidies, increasing demand uncertainty and the need to move away from long term RTC contracts. It is hoped that the commission takes cognizance of these issues and uses the upcoming MYT process as an opportunity to initiate a consultative transition plan for the sector.

Tata Power (Distribution) has filed a petition with the MERC for approval of additional surcharge from 2016-17 onward.

The Additional Surcharge is a mechanism to compensate utilities for the fixed cost of their long-term contracted capacity, which is stranded as a result of consumers moving to Open Access (OA). Prayas (Energy Group) presented at the public hearing held on December 14, 2017 in Mumbai and submitted that TPC-D's petition was not legally maintainable. In addition, the regulations do not allow for restrospective application of Additional Surcharge and all of TPC-D's existing power purchase agreements are about to expire in March 2018, providing an opportunity to the MERC and TPC-D to plan future power procurement in a manner that results in no stranded capacity. Hence, even going forward there is no case for applying additional surcharge.

Both the presentation and the submission made by PEG can be downloaded using the links below.

The implementation of fuel surcharges has been strongly advocated by the Union Government as a measure to alleviate the financial predicament of DISCOMs. In this context, the report studies the various processes, methodologies, and practices across states to determine, levy, and recover fuel surcharges.

Fuel surcharges which are typically levied on a monthly basis and revised every quarter enable timely recovery of costs incurred over and above approved tariffs. Therefore, they ease the working capital woes of the DISCOM. This, in turn, also reduces the burden of carrying cost on consumers.

As the impact on consumers can be significant, any process for its determination and levy should ensure transparency, accountability, and public participation. Considering this, the report covers developments in Assam, Andhra Pradesh, Bihar, Chhattisgarh, Gujarat, Haryana, Himachal Pradesh, Karnataka, Kerala, Madhya Pradesh, Maharashtra, Punjab, Rajasthan, Uttar Pradesh and West Bengal.

This report highlights common trends and draws lessons for a national framework for implementation of fuel surcharges. Such a framework can ensure timely recovery of prudent costs for DISCOMs while being acceptable to consumers.

On 6th October 2017, the Maharashtra Electricity Regulatory Commission (MERC) vide its order in case no 135 of 2017 allowed the Maharashtra State Electricity Distribution Company Ltd (MSEDCL) to procure around 1000 MW of short-term power at higher cost than the ceiling rate of Rs. 4 per unit that the commission had set for such procurement about a year ago. The reason for this was that MSEDCL claimed that around 6600 MW of its contracted capacity was unavailable due to coal shortage. As a result of this, MSEDCL was also forced to undertake distress load shedding in the state. Out of MSEDCL’s total contracted capacity of 33,496 MW, more than one-third belongs to Maharashtra State Power Generation Company Ltd (MSPGCL) and more than 60% of MSPGCL’s coal based capacity was unavailable during this period. It is important to note that the claims regarding coal shortage made by MSPGCL are contrary to the public statements made by the Ministry of Coal regarding coal availability and the data published by Coal India Ltd (CIL) regarding coal production and supply. Hence, it becomes important to evaluate whether the coal shortage claimed by MSPGCL and some other generators in the state could have been avoided by better planning.

Therefore, in order to bring in more clarity regarding coal procurement and generation planning processes, Prayas (Energy Group) has filed a petition before the MERC seeking a thorough analysis and examination of the reasons leading to sudden fall in availability of MSEDCL’s contracted capacity during September 2017. Prayas has demanded that the MERC should undertake such analysis based on data such as actual indents issued by MSPGCL to the concerned coal companies for coal requisition, coal supplied by CIL against such indents, and the details regarding how MSPGCL is utilising the coal supply contracted for its capacity (4522 MW) that is under planned economic and/or reserve shut down.

Prayas has submitted that the crisis like situation that emerged in September 2017 should be used as an opportunity to thoroughly evlauate generation planning and coal procurement processes in the state. Based on this analysis and to avoid such issues in future, the Commission should consider issuing specific process directions to the concerned companies. The petition is yet to be listed for hearing before the Commission.

Maharashtra State Power Generation Company Limited (MSPGCL) has filed a petition for capital cost and tariff determination of Koradi Units # 8, 9, & 10, Chandrapur Uinits # 8 & 9 and Parli Unit-8. The petition along with copy of the public notice can be downloaded from here. A public hearing in this regard was conducted by the Maharashtra Electricity Regulatory Commission (MERC) on 26th October 2017. Prayas participated in the hearing and made a submission which is attached below.

Prayas (Energy Group) convened a two day experience sharing workshop involving more than 40 civil society actors from 14 states. Decades after the reform process the sector continues to be a in a state of flux with several technological and structural changes adding to the complexity, challenges and uncertainty. Addressing this emerging scenario requires agile, forward looking and innovative approaches by all stakeholders including DISCOMs, Regulatory Commissions and Consumers. In this context, the objective of the workshop was to improve the understanding and engagement of civil society groups in the state electricity sectors through experience sharing.

Through state-level presentations and discussions on key issues such as power procurement, supply and service quality, rural electrification, regulatory governance and ensuring effective consumer participation the participants deliberated key aspects of the emerging scenario and discussed approaches for a way forward.

During the proceedings of the workshop each participant gained more ideas for continuing engagement with the sector in their own areas of work with an informal network for support.

This workshop is expected to be a first step of such interactions, and more such events will be organised over a period of time.

The participants also shared notes and presentations before and during the event. The notes and presentations cover issues in the states of Andhra Pradesh, Bihar, Jharkhand, Karnataka, Kerala, Madhya Pradesh, Maharashtra, Odisha, Punjab, Rajasthan, Telangana, Tamil Nadu, Uttar Pradesh and West Bengal.

A brief context setting presentation by Prayas (Energy Group), report on the proceedings at the workshop (along with a list of participants) and the notes and presentations shared by participants on state level issues are available here.

Thursday, 28 September 2017 14:02

Will there be light on December 31, 2018?

On September 25, 2017, the Prime Minister announced 'Saubhagya'  a new programme to provide connections to all households by December 2018. While welcoming this initiative, Prayas has written this short article to emphasise that electrification challenge today is beyond giving connections. This article appeared in The Wire on September 27, 2017.

The Ministry of Power on the 24th of August 2017  released a consultation paper to discuss issues pertaining to open access. This is a welcome initiative and provides a framework to all actors for a way forward to address issues with sales migration. In this context, Prayas (Energy Group) submitted comments and suggestions to the Ministry. Some comments and suggestions include:

  1. Suggestions to ensure a phase-wise transition away from short term open access.
  2. Widening the scope of the consultation paper to include captive sales migration.
  3. DSM mechanism for distribution open access consumers to address scheduling issues.
  4. Ensuring certainty in CSS and using CSS design to encourage long term open access.
  5. Need for transition support for DISCOMs facing sales migration as CSS, Additional surcharge will not compensate for loss of revenue.
  6. Suggestions for a process and methodology followed by SERCs to determine additional surcharge.
  7. Designing standby charges to provide standby services and encourage open access consumers to find alternate standby options.
  8. Phase-wise removal of concessions on cross subsidy surcharge, additional surcharge, wheeling and transmission charges in the absence of subsidy support to compensate DISCOM for costs incurred.
  9. Need for innovative tariff solutions and comments on how increasing fixed charges will be counter-productive for the DISCOM in its efforts to prevent sales migration.
  10. Need for data and information from open access consumers, generators, trading licensees, DISCOMs, ERCs, SLDCs to better understand and prepare for emerging trends.
  11. Need for a market monitoring committee constituted by every ERC with experts and representatives of DISCOM, traders, SLDC, ERC, open access and captive generators and consumers which releases an annual report with inter-state and intra-state market trends.
  12. Methodology for determination of energy banking charges for renewable energy based open access.

Please find below Ministry of Power's consultation paper and Prayas (Energy Group)'s comments on the same.

NITI Aayog published a Draft National Energy Policy in June 2017 and invited comments. Following are the comments submitted by PEG for the same.

The Government of India announced a new policy called SHAKTI to allocate coal to power sector consumers in May 2017. This article analysing SHAKTI and its impact on the power and coal sectors was published in Business Standard of 25th June 2017. It concludes that, while the policy announcement will bring in short-term relief, it is unlikely to contribute to the long-term goals of the sector which requires efficient thermal generation, competitive markets and flexible contracts. Instead, it could fragment coal and power generation along public and private sector lines, with consumers having to bear the costs of the resultant inefficiencies.

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