Draft Petition
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WITH REFERENCE TO THE PUBLIC NOTICE ISSUED IN ……………….. DATED……………
INVITING OBJECTIONS AND SUGGESTIONS FROM THE STAKEHOLDERS, THE RESPONDENT,
BYRNIHAT INDUSTRY ASSOCIATION IS SUBMITTING THE OBJECTIONS TO THE PETITION
FILED BY THE MEGHALAYA POWER DISTRIBUTION COMPANY LIMITED (HEREINAFTER
REFERRED AS MePDCL) SEEKS THE APPROVAL OF ANNUAL REVENUE REQUIREMENT AND
DETERMINATION OF TARIFF FOR FINANCIAL YEAR 2014-2015.
THE RESPONDENT IS AN ASSOCIATION OF THE INDUSTRIES IN THE BYRNIHAT AREA AND PLAY A MOST IMPORTANT & VITAL ROLE IN THE REVENUE OF MEGHALAYA AS WELL AS THE MEGHALAYA ENERGY CORPORATION LIMITED, THE HOLDING COMPANY.
AT THE OUTSET, IT IS SHOWED THAT THOUGH THE MePDCL HAS FILED THE PETITION IN ACCORDANCE WITH THE MEGHALAYA STATE ELECTRICITY REGULATORY COMMISSION (DETERMINATION OF TARIFF) REGULATIONS 2011, NOTIFIED BY THIS HON’BLE COMMISSION. HOWEVER THERE ARE VARIOUS INCONSISTENCIES IN THE PETITION AS WHAT IS PRACTISED IN THE LAST YEAR. WHILE FILING THE PETITION FOR APPROVAL OF ARR AND TARIFF FOR FINANCIAL YEAR 2014 – 15, MePDCL PLACED THE ACTUAL DATA OF 2013 – 14 WHICH WILL AGAIN REQUIRED TRUING UP EXERCISE BY THE HON’BLE COMMISSION.
IT IS ALSO NEED TO MENTION THAT IN THE PETITION FILED BY THE MePDCL, THE DATA PRESUMED IS VERY HIGH AND ABSURD. IT IS ALSO SEEN THAT MePDCL HAS CLAIMED THE ANNUAL REVENUE REQUIREMENTS UNDER ALL HEADS ON PROJECTED DATA WHICH IS UNCLEAR AND WITHOUT ANY BASIS. THOUGH THE REPEATED REQUEST FROM INDUSTRY ASSOCIATION IN THE LAST YEARS ADVISORY MEETINGS AND HEARINGS TO SHOW THE EXACT AUDITED DATA SO THAT THE ASSOCIATION ALSO CAN GET A CLEAR PICTURE OF ALL HEADS OF PROJECTED DATA AND THAT CAN ALSO UNDERSTAND THE REQUIREMENT OF THE MePDCL PROJECTED ARR.
WHILE PRESENTING THE PETITION FOR APPROVAL OF ARR AND DETERMINATION OF TARIFF, IT APPEARS THAT MePDCL DIDN’T THINK IT NECESSARY TO REVIEW THE LAST YEAR’S DIRECTIVE OF THE HON’BLE COMMISSION TO GIVE THE TRUE AND AUDITED REPORT & DATA WHILE FORECASTING THE ARR. IT IS SEEN IN MANY HEADS THAT THE COMMISSION’S DIRECTIVE IS BEING NEGLECTED. WITHOUT TRUING UP EXERCISE AND AUDITED DATA THE PRESENT ARR IS NOTHING BUT WASTING OF VALUABLE TIME & ENERGY OF INDUSTRY REPRESENTITIVES, BUREAUCRATS OF THE CONCERNED DEPARTMENTS AND HON’BLE COMMISSION.
THE MAIN OBJECTIONS OF THE BYRNIHAT INDUSTRY ARE AS FOLLOWS:
IN THE PRESENT ARR THE MePDCL PROPOSED Rs. 489.08 Cr. FOR POWER PURCHASE, AGAINST THE APPROVED 480.64 Cr. IN THE LAST YEAR. IT IS SEEN THAT IN THE FY 2014-2015 THE NO. OF CONSUMERS AND THE CONSUMPTION IS ALMOST SAME AS THE NO. OF NEW CONNECTION ALLOTED IS VERY FEW AND NO NEW INDUSTRIAL CONSUMER IS REGISTERED IN NEW FINANCIAL YEAR. THE 1.75% INCREASE IN THE POWER PURCHASE COST IS THE EXTRA BURDEN TO THE CONSUMERS WITHOUT ANY VALID REASON AND IT MUST BE RULED OUT. IT IS ALSO SEEN THAT MePDCL FAILED TO PRESENT THE EXACT DATA AND REQUIOREMENT OF POWER PURCHASE AND PRESENTED THE SAME AS IN THE LAST YEAR’S (2013-14) ARR.
MePDCL HAS PROPOSED Rs. 123.48 Cr. FOR TRANSMISSION COST FOR FY 2014-2015, WITHOUT ANY SUPPORTING DATA AGAINST THE LAST APPROVED 116.26 Cr. WHICH IS 6.21 % MORE THAN THE PREVIOUS YEARS APPROVED FIGURE. IT IS REQUESTED BEFORE THE HON’BLE COMMISSION NOT TO PASS THIS MUCH OF HIGHLY INFLATED FIGURE WITHOUT ANY AUDITED SUPPORTING DATA PRESENTED BY THE PETITIONER (MePDCL).
OPERATION AND MAINTENANCE EXPENSES
REGULATION 76 OF THE TARIFF REGULATIONS, 2011 READ AS UNDER-
“76. OPERATION AND MAINTAENANCE EXPENSES
(1) OPERATION AND MAINTENANCE EXPENSES OR O & M EXPENSES SHALL MEAN THE TOTAL OF ALL EXPENDITURE UNDER THE FOLLOWING HEADSS:-
(a) EMPLOYEE COST
(b) REPAIRS AND MAINTENANCE
(c) ADMINISTRATION & GENERAL EXPENSES.
(2) THE LICENSEE SHALL SUBMIT O & M EXPENSES BUDGET INDICATING THE EXPENDITURE UNDER EACH HEAD OF ACCOUNT SHOWING ACTUALS OF THE LAST FINANCIAL YEAR, ESTIMATES OF THE CURRENT YEAR AND PROJECTIONS FOR THE NEXT FINANCIAL YEAR.
(3) THE NORMS FOR O & M EXPENSES ON THE BASIS OF CIRCUIT KILOMETERS OF TRANSMISSION LINES, TRANSFORMATION CAPACITY AND NUMBER OF BAYS IN SUBSTATION SHALL BE SUBMITTED FOR APPROVAL OF THE COMMISSION.
(4) THE COMMISSION SHALL VERIFY THE BUDGET ESTIMATES THE PROJECTIONS AND ALLOW THE EXPENDITURE DEPENDING ON ITS VIEWS ABOUT THE REASONABLENESS OF THE PROJECTIONS.
(5) INCREASE IN O & M EXPENSES DUE TO NATURAL CALAMITIES OR INSURGENCY OR OTHER FACTORS NOT WITHIN ITS CONTROL MAY BE APPROVED BY THE COMMISSION.”
EMPLOYEE EXPENSES
REGARDING EMPLOYEE EXPENSES MePDCL NEEDS TO SUBMIT ARR AS PER THE REGULATION 76 (2) AS ABOVE BASE THE CLAIM ON DIFFERENT HEADS. IN THE LAST YEAR 2013-14 ARR, MePDCL HAS PROPOSED Rs. 114.28 Cr. AGAINST WHICH THE HON’BLE COMMISSION HAS APPROVED Rs. 95 Cr. NOW IN THE PRESENT ARR 2014-15, MePDCL IS PROPOSED Rs. 163.8 Cr. AS EMPLOYEE EXPENSES WHICH IS 72 % MORE THAN THE LAST YEAR’S APPROVED ARR AND THE CLAIM TO GET THE PROPOSED AMOUNT IS NO WHERE APPEARS TO BE VALID AS IT IS CLEARLY INDICATED INCONSISTENCIES IN THE PROJECTIONS.
REGARDING REPAIR AND MAINTENANCE EXPENSES, AGAIN REGULATION 76 WILL APPLY AND IT RELATES TO THE ASSETS BEING MAINTAINED BY THE DISTRIBUTION LICENSEE. NO SUCH INFORMATION IS PROVIDED BY THE LICENSEE IN THE PRESENT ARR. THE HON’BLE COMMISSION IS REQUESTED TO PASS THE MINIMUM POSSIBLE BUDGET FOR REPAIR AND MAINTENANCE.
MePDCL HAS PROPOSED THE ADMINISTRATION & GENERAL EXPENSES Rs. 9.25 Cr. IN THE PRESENT ARR 2014-15, WHICH IS 45 % MORE THAN THE LAST YEAR’S APPROVED ARR, WHICH AGAIN IS HIGHLY INFLATED AND SHOWS INCONSISTENCIES WHILE PROJECTING THE ARR. IT IS REQUESTED BEFORE THE HON’BLE COMMISSION TO GIVE DIRECTION TO THE MePDCL TO PROVIDE THE DETAILS OF THE ASSETS MAINTAINED BY THEM AND THEIR CAPACITY SUCH AS TRANSMISSION LINES AND NUMBER OD SUBSTATIONS ETC. TO REMOVE ANY ARBITRAINESS IN THIS PROJECTION.
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