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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
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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