Before the Madhya Pradesh Electricity Regulatory Commission, Bhopal

Transcription

1 Table of Contents 1 Comparison of Claimed and Allowed Annual Revenue Requirement for FY Power Purchase Cost and Intra State Transmission Charges Operation & Maintenance (O&M) Cost Interest & Finance Charges Interest on Project Loans Interest on Working Capital Loans Interest on Consumer Security Deposit Depreciation and Related Debits Bad and Doubtful Debts Other Expenses / Prior period expense Return on Equity Taxes Other Income: Sales Summary of True Up for the FY Submission on Carrying Cost of revenue gap PRAYER Before the Madhya Pradesh Electricity Regulatory Commission, Bhopal Page 1 of 23

2 Filing : Case : of 2013 Madhya Pradesh Paschim Kshetra Vidyut Vitaran Company Limited, (MPPKVVCL), GPH Compound, Polo Ground, Indore (MP) Petitioner IN THE MATTER OF: Filing of application for True up of the Annual Revenue Requirement (ARR) for FY under the principles laid down in the Madhya Pradesh Electricity Regulatory Commission (Terms and Conditions for Determination of Tariff for Supply and Wheeling of Electricity and Methods and Principles for Fixation of Charges) Regulations, 2009 (G-35 of 2009) dated December, 2009 by the Madhya Pradesh Paschim Kshetra Vidyut Vitaran Company Ltd., Indore as the Distribution Licensee. 9 th The Petitioner above named, M.P. Paschim Kshetra Vidyut Vitaran Company Ltd., Indore, respectfully submits as under:- Madhya Pradesh Paschim Kshetra Vidyut Vitaran Company Ltd. (MPPKVVCL), (hereinafter referred to as the Petitioner, West Discom, (the Company or the Licensee ), is a Company incorporated under the Companies Act, 1956 and having its registered office at GPH Compound, Polo Ground, Indore. The Petitioner is a deemed licensee under the Fifth Proviso to Section 14 of the Electricity Act, The area of supply of the Petitioner is Indore and Ujjain Commissionaires within the State of Madhya Pradesh ( MP ). The Government of Madhya Pradesh ( GoMP or State Government ), vide an Order FRS dated 31st May, 2005, published in the gazette of Madhya Pradesh dated 31st May 2005, have restructured the functions and undertakings of Generation, Transmission, Distribution and Retail Supply of electricity earlier carried out by the Madhya Pradesh State Electricity Board ( MPSEB or the Board ) and transferred the same to five Companies to function independently. The five Companies are as under: - o M.P. Power Generating Company Ltd., Jabalpur (MPPGCL) (GENCO); o M.P. Power Transmission Company Ltd., Jabalpur (MPPTCL) (TRANSCO); o M.P. Poorv Kshetra Vidyut Vitaran Company Ltd., Jabalpur (MPPKVVCL) (EAST DISCOM); o M.P. Madhya Kshetra Vidyut Vitaran Company Ltd. Bhopal (MPMKVVCL) (CENTRAL DISCOM); o M.P. Paschim Kshetra Vidyut Vitaran Company Ltd., Indore (MPPKVVCL) (WEST DISCOM); With effect from 1st June 2005, the Operation and Management Agreement that existed between MPSEB and the Five Companies came to end with the issue of the said Order dated Page 2 of 23

3 31 st May The three Vidyut Vitaran Companies viz. East Discom, Central Discom and West Discom, started functioning independently as Distribution Licensees in their respective area of license and from the said date are no longer operating as an agent of or on behalf of the Board, subject to Cash Flow Mechanism (CFM) provided in the said Order. On 3 rd June 2006 GoMP, in exercise of its powers under Section 23 (Sub-section (1), (2) and (3)) and Section 56 (Sub-section (2)) of Madhya Pradesh Vidyut Sudhar Adhiniyam, 2000 read with Section 131 (Sub-sections (1), (2), (5), (6) and (7) of Electricity Act, 2003, effected the transfer of and vesting of the functions, properties, interests rights and obligations of MPSEB relating to the Bulk Purchase and Bulk Supply of Electricity in the State Government and simultaneously re-transferred and re-vested the same to MP Power Trading Company ( Tradeco or 'MP Tradeco'). Since then, MP Tradeco is discharging the responsibilities of procurement of power in bulk and supplying to the three Discoms, including the Petitioner herein. The transfer was effected through M.P. Electricity Reforms Transfer Scheme Rules 2006 (Transfer Scheme Rules) vide Notification 3474 /FRS/17/XIII/2002 dt 3rd June 2006 (Transfer Scheme Rules). The Government of Madhya Pradesh ( GoMP or State Government ), vide an Order FRS XIII dated 12 th June, 2008, published in the gazette of Madhya Pradesh the final opening balance sheets of the companies. The effect of differences between provisional and final opening balance sheet have been taken in audited annual statement for FY of the company. Hon ble Commission had notified the Tariff Order for the period FY dated 18th May 2010 relating to the petition numbers 03/10, 04/10 and 05/10 filed by East Discom, Central Discom and West Discom respectively for determination of tariff for distribution and retail supply of electricity to the consumers in respective areas of supply during FY In the backdrop of the above facts and circumstances, the present application is being made by the Petitioner (West Discom) under Section 61 and Section 62 (1) (d) of the Electricity Act 2003, read with Clause 1.38 A of the The Madhya Pradesh Electricity Regulatory Commission (Details to be furnished and fee payable by Licensee or generating company for determination of tariff and manner of making application) Regulations, 2004(Third Amendment) [AG-13(iii) of 2008) dated 19th December 2008 and clause 8 of the The Madhya Pradesh Electricity Regulatory Commission (Terms and Conditions for Determination of Tariff for Supply and Wheeling of Electricity and Methods and Principles of Fixation of Charges) Regulations, 2009 (G-35 of 2009) dated 9 th December 2009 for truing up of the ARR for the Distribution and Retail Supply Business for the period FY Based on the information available, the Petitioner has made sincere efforts to comply with the Regulations of the Hon ble Commission and discharge its obligations to the best of its abilities and resources of its command. However, should any further material information become Page 3 of 23

4 available during the process of determination, the Applicant be permitted to reserve the right to file such additional information and consequently amend/ revise the application. Shri Kailas Shiva C.E. (Commercial) of Madhya Pradesh Paschim Kshetra Vidyut Vitaran Co. Ltd. (MPPKVVCL) has been authorized to execute and file all the documents on behalf of MPPKVVCL in this regard. Accordingly, the current filing documents is signed and verified by, and backed by the affidavit of Shri Kailas Shiva C.E.(Commercial). Page 4 of 23

5 1. Comparison of Claimed and Allowed Annual Revenue Requirement for FY West Discom in their petition dated 11 th January 2010 and subsequent submission for the FY has submitted claims for Net ARR of Rs Cr. Hon ble Commission in the Tariff Order dated 18 th May 2010, allowed Net ARR of Rs Cr. only. Head-wise comparison is given in following table; Claimed in the ARR Petition (A) Allowed in the Tariff Order (B) Variation 1 Power Purchase Cost Transmission Cost O&M Cost (including MPERC Fees) Interest and Finance Charges Depreciation and Related Debits Return on Equity Provision for Bad Debts Gross ARR Less: Other Income Net ARR With the Audited Accounts of West Discom for the period FY , the actual cost has been compared with the Allowed Cost head wise and details of which have been provided in the subsequent Chapters. 2. Power Purchase Cost and Intra State Transmission Charges West Discom in its ARR petition for FY had submitted power purchase requirement of MUs whereas the total power purchase requirement approved in the Tariff Order was MUs. The cost allowed for power purchase was at Rs Cr. Claimed in the ARR Petition (A) Allowed in the Tariff Order (B) Variance 1 Power Purchase Requirement (In MUs) Power Purchase Cost (In Rs. Cr.) Transmission Cost (In Rs. Cr.) As per Audited Accounts, West Discom has purchased MU s power during the year In the tariff order, the quantum of power allowed was MU. Accordingly, the Discom has purchased MU s higher than allowed in tariff order for the year The total cost of power purchase was Rs as per audited accounts. The transmission cost as per the bills received was Rs crore. Page 5 of 23

6 Actual as per Audited Accounts (A) Allowed in the Tariff Order (B) Variation 1 Power Purchase Requirement (In MUs)* Power Purchase Cost (In Rs Cr) Transmission Cost (In Rs Cr) The licensee, thus requests for a true up of Rs Cr. ( for power purchase & (10.21) for transmission charges) on this account. The month wise details of power purchase bills are as under: Summary of Energy billed during FY S. Month/Period Bill / date Unit billed (In Amount of bill (Rs. In crore) MU S) 1 Apr-10 Tradeco/Dicom/WZ/M.Energybill/03/April-10/ May-10 Tradeco/Dicom/WZ/M.Energybill06/May Jun-10 Tradeco/Dicom/WZ/M.Energybill/09/June 10/ Jul-10 Tradeco/Dicom/WZ/M.Energybill/12/July Aug-10 Tradeco/Dicom/WZ/M.Energybill/15/Aug 10/ Sep-10 Tradeco/Dicom/WZ/M.Energybill/18/Sept.10/ Oct-10 Tradeco/Dicom/WZ/M.Energybill/21/Oct 10/ Nov-10 Tradeco/Dicom/WZ/M.Energybill/24/Nov 10/ Dec-10 Tradeco/Dicom/WZ/M.Energybill/27/Dec 10/ Jan-11 Tradeco/Dicom/WZ/M.Energybill/30/Jan 11/ Feb-11 Tradeco/Dicom/WZ/M.Energybill/33/Feb 11/ Mar-11 Tradeco/Dicom/WZ/M.Energybill/36/March UI Bill for the Apr UI bill for the May UI bill for the June Revised UI bill for the Apr 10 to June UI bill for the July UI bill for the Aug UI bill for the Sep 10 Scheduled Energy Debit Note 07-05/SG-11/UI/ Debit Note 07-05/SG-11/UI/ Debit Note 07-05/SG-11/UI/ Debit Note 05-01/F&A/ Debit Note 07-05/SG-11/UI/ Debit Note 07-05/SG-11/UI/ Debit Note 07-05/SG-11/UI/ Page 6 of 23

7 20 UI bill for the Debit Note 05-01/F&A/121 Oct UI bill for the Debit Note 05-01/F&A/255 Nov UI bill for the Debit Note 05-01/F&A/401 Dec UI bill for the Debit Note 05-01/F&A/736 Jan UI bill for the Debit Note 05-01/F&A/881 Feb UI charges RC charge for the Debit Note 07-05/SG-11/REC/1438 Apr RC charge for the Debit Note 07-05/SG-11/REC/1438 May RC charge for the Debit Note 07-05/SG-11/REC/1564 June RC charge for the Credit Note 07-05/SG-11/REC/1700 July RC charge for the Credit Note 07-05/SG-11/REC/127 Aug RC charge for the Sep 10 Debit Note 07-05/SG-11/REC/ RC charge for the Deibit Note 07-05/SG-11/REC/189 Oct RC charge for the Debit Note 07-05/SG-11/REC/324 Nov RC charge for the Debit Note 05-01/F&A/500 Dec RC charge for the Debit Note 05-01/F&A/759 Jan RC charge for the Debit Note 05-01/F&A/1010 Feb RC charge for the Credit Note 05-01/F&A/1009 March Reactive Energy Charges 2.45 Total energy billed for the year Bills pertains to previous periods Page 7 of 23

8 36 Revised REC for the period Nov 09- March Revise/Suppl. bill for year April/09 To March/10 39 UI Bill for Nov 09 to March 10 Debit Note 05-01/F&A/239 Tradeco/Dicom/WZ/M.Energybill/03/April Tradeco/Dicom/WZ/UI/Nov 09-March 10/ Total Previous bills Total The Copy of Power Purchase bills & Transmission charges bills are enclosed as Annexure Operation & Maintenance (O&M) Cost The licensee in its petition for FY had submitted for a O&M cost of Rs Cr. (Net of expenses capitalized amounting to Rs Crore). Hon ble Commission in its Tariff Order for the period FY had approved the Net O&M Expenses for period FY based on the Madhya Pradesh Electricity Regulatory Commission (Terms and Conditions for Determination of Tariff for Supply and Wheeling of Electricity and Methods and Principles for Fixation of Charges) Regulations, 2009 (G-35 of 2009) dated 9 th December, Details of O&M Expenses claimed by the Licensee and approved in the Tariff Order is as shown in the table below: Claimed in the ARR Petition (A) Allowed in the Tariff Order (B) Variation 1 Employee Cost (Excluding Arrear & Terminal Benefits) Terminal Benefit including earned leave encashment but excluding pension & gratuity 3 6 th Pay Arrear Administrative & General Expenses (Including MPERC Fees and other fees & taxes) Repair & Maintenance Expenses Total O&M Charges Hon ble Commission has approved Net O&M Expenses to an extent of Rs Cr. which is based on the norms as provided in the Terms and Conditions of Tariff Regulation, The Page 8 of 23

9 licensee has computed O&M Cost for the period of FY based on actual figures available as per the Audited Accounts. Details of O&M Expenses as approved in the Tariff Order and actual as per audited accounts are as shown in the table below: 1 2 Employee Cost (Excluding Arrear & Terminal Benefits) Terminal Benefit including earned leave encashment on payment basis but excluding pension & gratuity Actual as per Audited Accounts (A) Allowed in the Tariff Order (B) Variation th Pay Arrear Administrative & General Expenses (Including MPERC Fees) Repair & Maintenance Expenses Total O&M Charges The licensee, thus requests for a true up of Rs Crore on account of O&M Expenses. It may be noted that the licensee has prayed for allowing Rs Crore expenses (item 2 nd above) as Terminal Benefits including leave encashment but excluding Pension and Gratuity which has actually been paid by the Licensee to the retirees, and which is not being claimed by or allowed as a pass through expenditure in MP Transco s ARR. The details of the same are as under: Detail of terminal benefits paid by Discom excluding pension & Gratuity: S. No (In Rs. Crore) Amount 1 Earned Leave Encashment TERMINAL BENEFITS (PF) BOARD'S CONTRIBUTION TERMINAL BENEFITS (FPS) BOARD'S CONTRIBUTION PROVIDENT FUND INSPECTION AND AUDIT CHARGES COMPASSIONATE FINANCIAL ASSISTANCE TERMINAL BENEFIT G.T.I.S. CONTRIBUTION TERMINAL BENIFITS OTHER TERMINAL BENIFITS UNDER ANNUITY SCHEME FREE ELECTRICITY TO THE RETIRED EMPLOYEES Total Page 9 of 23

10 Since as per the provisions of the clause 32.1 of Tariff Regulations, all the Terminal benefits paid by Licensee are to be treated as allowable expenditure for the purpose of ARR/ Tariff, it is requested that the aforesaid expenditure may please be allowed. 4. Interest & Finance Charges 4.1. Interest on Project Loans The Licensee in its ARR filing had given source wise loan and Interest and Finance Charges details. The interest and finance charges on project loans were Rs Cr. However, Rs Cr. was actually allowed in the Tariff Order including finance charges of Rs Cr. for the period FY Following are the details of the Interest on Project Loans and Finance Charges as claimed in the ARR filing Petition and that allowed in the Tariff Order for the period FY Interest and Finance Charges Claimed in the Petition (A) Allowed in the Tariff Order (B) Variance 1 State Govt. Loans PFC Loans REC Loans ADB Loans JBIC RGGVY Counterpart Funding Cost of raising finance and bank charges Gross IFC (Rs. Cr.) Less IFC Capitalized Net Interest and Finance charges (Rs. Cr.) Actual interest & finance charges on project loans as per the provision of the regulation are as under: Particular FY 06 Debt identified with GFA as on 1st June 2005 (Allocation of debt and equity to GFA as per the FY Tariff Order) % of addition to net GFA considered as funded through Loan net of consumer contribution Debt Repayment 4.41 Total Debt Associated with GFA as on 31st March FY 07 Debt identified with GFA as on 31st March % of addition to net GFA considered as funded through Loan net of consumer contribution Debt Repayment (Equal to depreciation allowed in the True-up order ) Total Debt Associated with GFA as on 31st March FY 08 Page 10 of 23

11 Debt identified with GFA as on 31st March % of addition to net GFA considered as funded through Loan net of consumer contribution Debt Repayment (Equal to depreciation allowed in the True-up order ) Total Debt Associated with GFA as on 31st March FY 09 Debt identified with GFA as on 31st March % of addition to net GFA considered as funded through Loan net of consumer contribution Debt repayment (Equal to depreciation as per regulation for FY ) Total debt associated with GFA as on 31st FY 10 Debt identified with GFA as on 31st March % of addition to net GFA considered as funded through Loan net of consumer contribution Debt repayment (Equal to depreciation claimed in the True-up petition of FY ) Total debt associated with GFA as on 31st FY 11 Debt identified with GFA as on 31st March % of addition to net GFA considered as funded through Loan net of consumer contribution Debt repayment (Equal to depreciation claimed in the True-up petition of FY ) Debt identified with GFA as on 31st March Average of Loan Balance Weighted average rate of interest (%) (as per Interest on Project Loans) 11.81% A Interest and Finance charges on Project Loans B Other finance charges 4.13 Total interest and finance charges on Project loans Details of Interest Expenses as approved in the Tariff Order and actual as per audited accounts are as shown in the table below: Particular Actual as per regulation (A) Allowed in the Tariff Order (B) Variance 1 Interest and Finance charges on Project Loans Other interest & Finance charges Total Interest The licensee thus requests for a true up of Rs Crore on account of Interest on project loan. Page 11 of 23

12 4.2. Interest on Working Capital Loans Based on the norms specified in the Terms and Conditions of Tariff Regulation, 2009 Hon ble MPERC approved nil cost against this item in the tariff order of FY Details of Interest on working capital claimed by the Licensee and approved in the Tariff Order is as shown in the table below: Claimed in the ARR Petition (A) Allowed in the Tariff Order (B) Variance 1 Interest on Working Capital However, the actual Interest on Working Capital for the period FY as per the provision of the regulation is as under: Sl. Actual A 1/6th of annual requirement of inventory for previous year 3.44 B Normative O&M expenses B i) 1/12th of total C Receivables C i) Annual Revenue (from wheeling charges and retail tariffs and charges) C ii) Receivables equivalent to 2 months average billing D Power Purchase expenses D i) 1/12th of power purchase expenses E Consumer Security Deposit F Total Working capital A + B i) + C ii) - D i) E G Rate of Interest 11.75% H Interest on Working capital 4.69 Details of Interest on working capital approved in the Tariff Order and actual as per audited accounts are as shown in the table below: Page 12 of 23

13 Actual as per Regulation (A) Allowed in the Tariff Order (B) Variance 1 Interest on Working Capital The licensee thus requests for a true up of Rs Crore on account of Interest on Working Capital Loans Interest on Consumer Security Deposit Interest on Consumer Security Deposit (CSD) as approved in the Tariff Order for the period FY was Rs Cr. which was based on the Security Deposit Regulations, 2004 read with subsequent Amendments to the Regulations and the Terms and Conditions of Tariff Regulation, However, the actual Interest on consumer security deposits for the period FY for the licensee was Rs Cr. Following are the details of Interest on Consumer Security Deposits: Actual as per the Audited Accounts (A) 1 Opening Balance of CSD Additional CSD received during the year Refunded to consumers during the year Closing balance of CSD at the end of the year (1+2-3) Allowed in the Tariff Order (B) Variance 5 Interest paid on CSD The licensee thus requests for a true up of Rs. 3.4 Crore on account of Interest on Working Capital Loans. As per above discussion the summary of total interest & finance charges are as follows: Particular Actual as per Accounts/ regulation (A) Allowed in the Tariff Order (B) 1 Interest and Finance charges on Project Loans Interest on Working Capital Loan as per regulation Interest on consumer Security Deposit as per accounts Variance Total Interest Page 13 of 23

14 Thus licensee requested that the Interest & Finance Charges amounting to Rs Crore may kindly be true up. 5. Depreciation and Related Debits Details of the Depreciation Expenses claimed by the Licensee in its ARR filing and Depreciation Expenses approved in the Tariff Order for the period FY is as follows: Claimed in the ARR Petition (A) 1 Land and Building rights Building & Civil Works Hydraulic Works Other Civil Works Plant & Machinery Line Cable Networks etc Vehicles Furniture & Fixtures Office Equipments 0.99 Allowed in the Tariff Order (B) Variance Total The details of Opening Balance of Gross Fixed Assets on 01 st April 2010, additions and deductions made during the period FY and the Closing Balance of the Gross Fixed Assets for the period FY which is as follows: Opening balance of GFA as on Change during the year (additions / deductions) Closing Balance of GFA as on Land & Land rights Building and Civil Works Hydraulic Works Other Civil Works Plant & Machinery Line Cable Networks etc Vehicles Furniture & fixtures Office Equipments Total (1 to 11) It is submitted that Licensee calculated depreciation as per the provision of the regulation which is as under: Page 14 of 23

15 Actual as per Provision of the Regulation (A) Allowed in the Tariff Order (B) Variance 1 Land and Building rights Building & Civil Works Hydraulic Works Other Civil Works Plant & Machinery Line Cable Networks etc Vehicles Furniture & Fixtures Office Equipments 0.43 Total Detailed depreciation model is also being submitted along with petition. Prayer In view of the position explained above, it is requested that the depreciation amounting to Rs Cr. may kindly be true up. 6. Bad and Doubtful Debts In the Tariff Order for the period FY the licensee had claimed Rs Cr. as Bad and Doubtful Debts however Hon ble Commission did not admitted any cost against this items. However, the actual Bad and Doubtful Debts written off during the FY is Rs Cr. (Including surcharge written off Rs Cr) and the provision made for Bad and Doubtful Debts is Rs Cr. for the period FY :- Amount 1 Bad and Doubtful Debts claimed by the Licensee in its ARR filing Bad and Doubtful Debts Approved in the Tariff Order Bad Debts written off as per the Audited Accounts Variance (3-2) Prayer In view of the position explained above, it is requested that the bad & doubtful debts amounting to Rs may kindly be permitted as allowable expenditure as per the norms fixed by Hon ble commission. Page 15 of 23

16 7. Other Expenses / Prior period expense The Licensee in its ARR filing for the period FY had not claimed any cost against this item. However, for the True Up exercise for the period FY the licensee submits that the amount towards prior period expenses including other expenses is Rs Cr details of which are as shown in the table below: Actual as per the Audited Accounts (A) Allowed in Tariff Order (B) Variance 1 Net prior Period Charges as per accounts Other Charges Net Total Other Expenses Prayer In view of the position explained above, it is requested that the other expenses amounting to Rs may kindly be permitted as allowable expenditure. 8. Return on Equity The licensee in its ARR filing for the period FY had claimed a Return on Equity of Rs Cr. However in the tariff order Hon ble Commission allowed RoE amounting to Rs Cr. Based on the Audited Accounts of FY & considering the provision of the regulation Licensee has calculated the RoE amounting to Rs Cr which as under: Particular FY 06 Equity identified with GFA as on 1st June 2005 (Allocation of Equity and equity to GFA as per the FY Tariff Order) % of addition to net GFA considered as funded through Equity net of consumer contribution Total Equity Associated with GFA as on 31st March FY 07 Equity identified with GFA as on 31st March 2006 (Allocation of Equity and equity to GFA as per the FY Tariff Order) % of addition to net GFA considered as funded through Equity net of consumer contribution Total Equity Associated with GFA as on 31st March FY 08 Equity identified with GFA as on 31st March 2007 as per True UP order of % of addition to net GFA considered as funded through Equity net of consumer contribution Page 16 of 23

17 Total Equity Associated with GFA as on 31st March FY 09 Equity identified with GFA as on 31st March 2008 as per True Up order % of addition to net GFA considered as funded through Equity net of consumer contribution Total Equity associated with GFA as on 31st FY 10 Equity identified with GFA as on 31st March % of addition to net GFA considered as funded through Equity net of consumer contribution Total Equity associated with GFA as on 31st FY 11 Equity identified with GFA as on 31st March % of addition to net GFA considered as funded through Equity net of consumer contribution Equity identified with GFA as on 31st March Total Equity associated with GFA as on 31st 2016 Rate of Return 16% Return on Equity Prayer In view of the position explained above, it is requested that the RoE amounting to Rs may kindly be allowed. 9. Taxes The licensee submits that for the period FY it has incurred a loss of Rs Cr. hence was not required to pay any Income Tax. 10. Other Income: The licensee in its ARR filing for the period had claimed Rs Cr. as other income. However, Rs. 100 Crs was approved in the Tariff Order for the period FY The licensee was able to earn Rs Cr. as other Income for the period FY and the details are as shown below: S. Allowed in Tariff Order (A) Actual as per Audited Accounts (B) (B)-(A) A Income from Investment, Fixed & Call Deposits 1 Interest on fixed deposits Details not available Sub-Total B Other Non Tariff Income Page 17 of 23

18 1 Interest on loans and Advances to staff Interest on Advances to Suppliers / 2 Contractors 3 Income from trading (Other than electricity) 1.99 Income/Fee/Collection against staff welfare activities Details not 5 Delayed payment surcharge from consumers available Miscellaneous receipts Sub-Total Total Other Income (A+B) Less: Delayed payment surcharge Less: Interest Income from Investments Less: Interest on Advances to Suppliers / 11 Contractors 7.29 Less : Income received from MPSEB (Included in Miscellaneous receipts) Net other Income Thus licensee request to the Hon ble Commission that R may be true up on account of other income. 11. Sales The Licensee hereby submits that the Hon ble Commission approved total sales of 9527 MU s. Actual sales during are MU which is higher by MU than approved in the tariff. The actual revenue as per audited accounts is (Including subsidy). Details of the same are as shown in the table below: Page 18 of 23

19 Rs in crore As per Tariff Order Actual (As per R-15) Variance Sales (MU) Revenues (Rs. Crs.) Sales (MU) Revenues (Rs. Crs.) Sales (MU) Revenues (Rs. Crs.) LOW TENSION LV 1: DOMESTIC 2, , LV 2: NON-DOMESTIC/COMMERCIAL LV 3: PUBLIC WATER WORKS AND STREET LIGHTS LV 4: LT INDUSTRY LV 5: IRRIGATION PUMP FOR AGRICULTURE 3, , , LT TOTAL 6, ,382 6, , HIGH TENSION HV 1: RAILWAY TRACTION HV 2: COAL MINES HV-3: INDUSTRIAL AND NON-INDUSTRIAL 2, ,226 2, , HV-4: SEASONAL HV-5: HT IRRIGATION AND WATER WORKS HV 6: BULK RESIDENTIAL USERS HV 7: BULK SUPPLY TO EXEMPTEES (RE Coop Society) HT TOTAL 3, ,606 3, , GRAND TOTAL HT + LT 9, ,987 10, , , GRAND TOTAL HT + LT as per R-15 (Including Meter Rent, Surcharge, Misc Charges etc) 4, GRAND TOTAL HT + LT as per Audited Accounts 3, Electricity Duty Recovery Other State Levies Recovery Meter Rent/Service Line Rental Recoveries for theft of Power/Malpractice Wheeling / U.I. Charges Recovery 4.19 TRUE UP PETITION OF ANNUAL REVENUE REQUIREMENT FOR FY Page-19

20 Misc. Charges From Consumers LESS :Electricity Duty Payable (CONTRA) Other State Levies Payable (CONTRA) GRAND TOTAL Revenue from Sale of Power as per Audited Accounts excluding subsidy 3, Subsidy From GoMP Revenue From Sale Of Power As Per Audited Accounts (Including Subsidy) 4, Page 20 of 23

21 12. Summary of True Up for the FY The licensee submits the Net ARR for the period FY at Rs Cr. and net GAP for true-up Rs. (613.52) Cr including carrying cost amounting to Rs after revenue from sale of power of Rs Cr. Summary of the Net ARR for the period FY is as follows : Allowed in the Tariff Order (A) Actual (B) Variance (B-A) 1 Power Purchase Cost 2, , Transmission Cost O&M Cost Interest and Finance Charges Depreciation and Related Debits Return on Equity Bad Debts Other expenses Income Tax Gross ARR 4, , Less: Other Income Net ARR (14-15) 3, , Revenue from sales of power 3, , (Gap) / Surplus for the Year Additional revenue due to true-up of MP Discom for the FY Total (GAP)/ Surplus before carrying cost Carrying cost on above revenue GAP Total Revenue (Gap)/surplus after considering Carrying Cost TRUE UP PETITION OF ANNUAL REVENUE REQUIREMENT FOR FY Page-21

22 12.1. Submission on Carrying Cost of revenue gap amounting to Rs Cr: It is submitted that on the same ground as explained above carrying cost amounting to Rs Cr., which pertain to revenue gap of Rs Crore, may also be allowed in this true-up petition. The calculation of the same is as under. Years (A) Interest Rate on Working capital loans as per Trueup/ ARR of the respective year (B) Opening eligible amount (C) Carrying cost (D) Closing eligible amount (E)=(C)+(D) (Half year) 14.25% % % Total Page 22 of 23

23 PRAYER In view of the aforesaid facts and circumstances, the Applicant requests that this Hon'ble Commission may be pleased to: a) Take the accompanying True Up Petition for the period FY of Madhya Pradesh Paschim Kshetra Vidyut Vitaran Co. Ltd. on record and treat it as complete. b) Consider and approve Madhya Pradesh Paschim Kshetra Vidyut Vitaran Co. Ltd. s True Up Petition with net ARR for the period FY at Cr. and net GAP of Rs. (613.52) Cr. c) Consider and approve the carrying cost on revenue GAP amounting to Rs Cr. d) Condone any inadvertent omissions/ errors/ shortcomings and permit the petitioner to add / change / modify / alter portions of this filing and make further submissions as may be required at a later stage; and e) Pass such order as the Hon'ble Commission may deem fit and proper in the facts and circumstances of the case in light of justice. Dated: Indore (Kailash Shiva) Chief Engineer MPPKVVCL, Indore Page 23 of 23