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A P R 2 0 1 3 MERC’s Public Hearing in the matter of RINFRA-D’s Multi Year Tariff for 2 nd Control Period FY 2012-13 to FY 2015-16 Case 9 of 2013 6 th April 2013 Sandeep N. Ohri Authorised Consumer Representative [email protected] 9833097575 1

Ohri Presentation at RINFRA-D's MYT Petition on 6th April 2013

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    MERCs Public Hearing in the matter of

    RINFRA-Ds Multi Year Tariff

    for 2nd Control Period

    FY 2012-13 to FY 2015-16 Case 9 of 2013

    6th April 2013

    Sandeep N. Ohri

    Authorised Consumer Representative

    [email protected]

    9833097575

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    MYT Business Plan Chronology

    11 Nov 2011: RInfra-D submits Affidavit Petition for MYT Business Plan FY 2011-12 to FY 2015-16

    26 Dec 2011: Data Gaps raised by MERC

    27 Dec 2011: More Data gaps raised by MERC

    28 Dec 2011: TVS held by MERC

    14 Jan 2012: RInfra-D submits responses

    01 Mar 2012: MERC raises more data gaps

    07 Mar 2012: RInfra-D submits responses

    10 Jul 2012: MERC raises more data gaps

    13 Jul 2012: RInfra-D submits responses 2

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    MYT Business Plan Chronology

    14 Jul 2012: MERC raises more data gaps

    18 Jul 2012: RInfra-D submits responses

    20 Jul 2012: RInfra-D files revised MYT Business Plan

    23 Jul 2012: MERC Admits Petition

    26 Jul 2012: RInfra-D issues Public Notice for hearing

    23 Aug 2012: Public Hearing held

    23 Nov 2012: MERC issues Order in this case

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    MYT Petition Filing

    25 Jan 2013: RInfra-D submits 2nd MYT Petition

    08 Feb 2013: MERC holds Tech Validation session

    14 Feb 2013: Affidavit signed RInfra-Ds Co. Secy. saying 2nd MYT Petition is attached

    15 Feb 2013: Meeting between MERC & RInfra-D and its minutes are attached to Affidavit dated 14th Feb!!

    16 Feb 2013: RInfra-D submits Revised Petition with explanations on Data gaps asked for by MERC

    Im not an expert at legal matters but is this acceptable?? 4

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    MYT Petition Filing

    The Business Plan for the 2nd MYT submitted by RInfra-D was discussed for over a year before final Order was issued by MERC on 23rd Nov 2012

    It is assumed that each data point, cost estimate and assumption was thoroughly deliberated upon

    The Tariff Petition, which flows from the Business Plan is filed 60 days later, on 25th Jan 2013

    This is discussed at MERC for less than 3 weeks and a revised Petition is readied for Public Release

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    Questions & Doubts

    MERC has admitted the revised Petition and allowed RINFRA-D to publish this for the Public Hearing

    It is assumed that the Revised Petition is in line with the Business Plan, which has been discussed for over a year

    Can MERC confirm that all issues raised by RInfra-D in the Revised published Petition

    Have been raised earlier in the Business Plan?

    Have been discussed in the TVS?

    Have been approved for public release?

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    Questions & Doubts

    If there are certain issues that were not raised, discussed and/or approved in the Business Plan and/or the TVS, is MERC going to allow those issues?

    Should they??

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    Sales Growth

    Rinfra-D anticipates Sales Growth at different rates for different categories

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    Sales Growth as per Business Plan

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    Category FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16

    LT Sales 8,017 8,231 8,462 8,714

    HT Sales 1,199 1,187 1,181 1,185

    Total Sales 9,216 9,418 9.643 9,899

    7.4%

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    Sales Growth(?) as per Petition

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    Category FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16

    LT Sales 8,297 7,318 6,670 6,829

    HT Sales 1,125 843 646 740

    Total Sales 9,422 8,161 7,316 7,569

    19.7%

    RInfra-D says that Cap Ex is required to cater to the growth !!

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    Sales Growth(?) in MUs

    Actual Sales data from Table 30

    MYT Petition Sales data from Table 1

    Business Plan Sales data from Table 4.2 & 4.3 of Order

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    7454 7807 8290 8528

    9008 9042 9216 9418 9643 9899

    9422

    8161 7316 7569

    06-07 07-08 08-09 09-10 10-11 11-12 12-13 13-14 14-15 15-16

    Actual Sales Business Plan MYT Petition

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    Capitalisation as per Business Plan

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    FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16

    Total 275 178 105 115

    TOTAL = Rs. 673 crores

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    Capitalisation as per Petition

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    FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16

    Total 365 392 494 498

    TOTAL = Rs. 1,749 crores Rs. 1,076 crores more than Bus. Plan projections!!

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    Distribution Loss

    As per Business Plan

    As per Petition

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    And Rinfra-D claims it has the best, award-winning, high-tech network in the country and yet cannot make consistent forecasts!

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    Power Purchase Requirement

    As per Business Plan

    As per Petition

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    Power Purchase As per Bus Plan

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    Power Purchase As per Petition

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    As per Business Plan = Rs. 11,654.46

    As per Petition = Rs. 14, 968.80

    Increase = Rs. 3,314.34 (UP 28%)

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    Summary of just 4 items!!

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    Bus Plan Petition Remarks

    Sales 38,176 MU 32,468 MU At Avge Tariff of Rs. 7.50 per unit, Revenue is lower by Rs. 4,000 cr

    Capitalisation Rs. 673 cr Rs. 1,749 cr Expense is higher by Rs. 1,076 cr

    Distribution Loss

    36.05% 37.69% 1.64% higher loss is additional purchase of 532 MU, at Avge cost of Rs. 4.20 per unit, is a hit of Rs. 223 cr

    Power Purchase

    Rs. 11,654 cr Rs. 14,969 cr Cost is higher by Rs. 3,315 cr

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    Prayers

    The filing of the Petition is suspect, because of the dates, and legal tenability needs to be verified

    It is extremely clear that the approved Business Plan has not been followed while making the MYT Petition and the Petitioner must be asked to revise the entire Petition

    Another Public Hearing needs to be held AFTER MERC has verified all data

    Strict action to be taken against MERC officials who were involved in the TVS of this Petition

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    Tamasoma jyotir gamaya (From darkness unto light)

    Contact: Sandeep N. Ohri

    Email: [email protected]

    Mobile: 98 33 09 7575

    Moderator: http://groups.yahoo.com/group/bijlee

    I sincerely thank the Honble Commission for this opportunity and for the time

    Thank you !!

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