HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE

REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

COMMISSION’S ORDER IN

HERC / Petition No. 69 of 2023

&
HERC / Petition No. 70 of 2023

IN THE MATTER OF

TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE

REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE REQUIREMENT
OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY
TARIFF FOR THE FY 2024-25.

05.03.2024

HARYANA ELECTRICITY REGULATORY COMMISSION

BAYS 33-36, SECTOR-4, PANCHKULA-134112, HARYANA
https://herc.gov.in

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

IN THE MATTER OF
ARR Petition for the FY 2024-25, Annual Performance Review for the FY 2023-24, and True-
up for FY 2022-23, under HERC (Terms and Conditions for Determination of Tariff for
Generation, Transmission, Wheeling and Distribution & Retail Supply under Multi Year
Tariff Framework) Regulations 2019 and Section 45, 46, 47, 61, 62, 64 & 86 of the Electricity
Act 2003 read with the relevant guidelines, by Uttar Haryana Bijli Vitran Nigam Ltd and
Dakshin Haryana Bijli Vitran Nigam Ltd.

Petitioner(s)
Uttar Haryana Bijli Vitran Nigam Limited (UHBVNL)
Dakshin Haryana Bijli Vitran Nigam Limited (DHBVNL)
Present on behalf of the Petitioner (UHBVNL)
1. Sh. Anurag Nanchahal, CFO/UHBVNL
2. Sh. Amit Gupta, IDAS, Director/Finance UHBVNL
3. Sh. Ashwani Kumar Raheja, Director OP
4. Sh. B.S. Kamboj, XEN- RA
5. Sh. Deepak Popli, SE, Commercial, Panchkula
6. Sh. Anil Kumar,AO, UHBVNL
7. Sh. Mohit Kumar, Sr. AO, UHBVNL
Present on behalf of the Petitioner (DHBVNL)
1. Sh. Rattan Kumar Verma, Director/Finance
2. Sh. Naresh Kumar Mehta, FA/HQ
3. Er. K. D. Bansal, SE/RA
4. Smt. Sushila Kumari, CAO
5. Urmila Grewal, XEN/RA
Present on behalf of the Intervenor
Sh. Varun Sharma, advocate for BPCL, IOCL & HPCL (Marketing Companies)

QUORUM

Shri Nand Lal Sharma Chairman

Shri Naresh Sardana Member
Shri Mukesh Garg Member

ORDER
The Haryana Electricity Regulatory Commission (hereinafter referred to as ‘the Commission’
or HERC), in exercise of the powers vested in it under section 61, 62 and 86 of the Electricity
Act, 2003 read with section 11 of the Haryana Electricity Reforms Act, 1997 and all other
enabling provisions in this behalf, passes this Order determining the True-up of the ARR for
the FY 2022-23, Annual (Mid-year) Performance Review for the FY 2023-24, Aggregate
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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Revenue Requirements and distribution and retail supply tariff of UHBVNL and DHBVNL for
their Distribution and Retail Supply Business under MYT framework for the FY 2024-25 in
accordance with the provisions of the Haryana Electricity Regulatory Commission (Terms and
Conditions for Determination of Tariff for Generation Transmission, Wheeling and
Distribution & Retail Supply under Multi Year Tariff Framework) Regulations, 2019 including
its subsequent amendments (hereinafter referred to as MYT Regulations,2019).

The Commission, while passing order in the present case(s), has considered the Petition(s)
filed by the Distribution Licensees viz. UHBVNL and DHBVNL along with the additional
submissions made by Discoms, and in the public consultation process, and all other relevant
material including:-
1. Subsequent filings/additional data provided by them including filings made by the two
distribution licensees in response to the various queries of the Commission
2. Objections received from various organisations and individuals
3. Reply/comments furnished by UHBVNL and DHBVNL on the objections filed.
4. State Advisory Committee (SAC) meeting held on 09.02.2024.
5. Relevant data / facts / policies available in the Commission and in public domain.
6. Feedback received in the public hearing held at Panchkula

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CONTENTS
CHAPTER 1 ................................................................................................................................... 7

INTRODUCTION ................................................................................................................ 7

1.1 BRIEF BACKGROUND................................................................................................................. 7

1.2 PRESENT PETITION ................................................................................................................... 8
1.3 PRINCIPLES OF TRUE UP FOR FY 2022-23 ...................................................................................... 8
1.4 SUMMARY OF TRUE UP OF FY 2022-23 (UHBVNL & DHBVNL) ..................................................... 10
1.5 ANNUAL PERFORMANCE REVIEW FOR FY 2023-24 (APR UHBVNL & DHBVNL) ................................ 13
1.6 AGGREGATE REVENUE REQUIREMENT (ARR) FOR FY 2024-25 ........................................................ 14
1.7 PRAYER ............................................................................................................................... 17
CHAPTER 2 ................................................................................................................................. 18

PROCEDURAL ASPECTS ................................................................................................... 18

2.1 ARR PETITION (UHBVNL & DHBVNL)...................................................................................... 18

2.2 PUBLIC NOTICE ..................................................................................................................... 18
2.3 OBJECTIONS FILED BY THE INTERVENERS, DISCOMS REPLY THERETO AND COMMISSION’S VIEW. ................ 19
2.3.1 M/S FARIDABAD INDUSTRIES ASSOCIATION (FIA) ......................................................................... 19
2.3.2 M/S DELHI METRO RAIL CORPORATION LTD. ............................................................................... 25
2.3.3 PANKAJ BHALOTIA ................................................................................................................. 30
2.3.4 AMINA CHAWLA, GMDA, GURUGRAM ...................................................................................... 40
2.3.5 B.K. AGGARWAL ................................................................................................................... 42
2.3.6 ANAGHA PUJARI .................................................................................................................... 52
2.3.7 VARUN SHARMA, ADVOCATE REPRESENTING BPCL, IOCL & HPCL ................................................... 54
2.4 PUBLIC HEARING ...................................................................................................................... 66
2.5 ADDITIONAL DATA/ INFORMATION FILED BY THE DISCOMS ............................................................... 67
2.6 STATE ADVISORY COMMITTEE (SAC)............................................................................................. 67
CHAPTER 3 ................................................................................................................................. 69

ANALYSIS OF ARR FILINGS AND COMMISSION’S ORDER .................................................. 69

3.1 TRUE-UP OF THE ARR FOR THE FY 2022-23 ................................................................................ 69

3.2 OPERATION & MAINTENANCE EXPENSES (O&M).......................................................................... 69
3.3 DEPRECIATION ...................................................................................................................... 75
3.4 INTEREST ON CONSUMERS SECURITY DEPOSIT............................................................................... 75
3.5 INTEREST ON CAPEX LOANS ...................................................................................................... 76
3.6 INTEREST ON WORKING CAPITAL LOAN ....................................................................................... 78
3.7 TOTAL INTEREST EXPENSES INCLUDING COST OF RAISING FINANCE AND BANK CHARGES .......................... 79
3.8 EXPENDITURE DUE TO OTHER DEBITS........................................................................................... 80
3.9 RETURN ON EQUITY (ROE) ....................................................................................................... 82
3.10 NON-TARIFF INCOME .............................................................................................................. 83
3.11 TRUE-UP OF POWER PURCHASE QUANTUM & COST ....................................................................... 85
3.12 REVENUE FROM SALE OF POWER (FY 2022-23)............................................................................ 88
3.13 REVISED ARR FOR THE FY 2022-23 AFTER TRUING-UP ................................................................... 90
3.14 REVENUE GAP OF THE DISCOMS FOR FY 2022-23 (RS. CRORE) ........................................................ 91

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 4 ................................................................................................................................. 94

ANNUAL PERFORMANCE REVIEW (APR) FOR FY 2023-24 ................................................ 94

4.1 BACKGROUND....................................................................................................................... 94
4.2 ENERGY SALES ...................................................................................................................... 95
4.3 TRANSMISSION LOSSES ........................................................................................................... 97
4.4 DISTRIBUTION LOSSES ............................................................................................................. 97
4.5 COLLECTION EFFICIENCY .......................................................................................................... 98
4.6 TRANSMISSION CHARGES......................................................................................................... 98
4.7 POWER PURCHASE COST ......................................................................................................... 98
4.8 ENERGY BALANCE .................................................................................................................. 99
4.9 CAPITAL EXPENDITURE .......................................................................................................... 101
4.10 COMPUTATION OF INFLATIONARY INDICES ................................................................................. 101
4.11 REVENUE ESTIMATION .......................................................................................................... 102
4.12 AGGREGATE REVENUE REQUIREMENT FOR FY 2023-24 ................................................................ 102
4.13 REVENUE GAP..................................................................................................................... 104
CHAPTER 5 ............................................................................................................................... 105

AGGREGATE REVENUE REQUIREMENT (FY 2024-25) ...................................................... 105

5.1 BRIEF INTRODUCTION ........................................................................................................... 105

5.2 ASSESSMENT OF AGRICULTURE TUBE WELL (AP) SALES: FY 2022-23 (TRUE UP), FY 2023-24 (REVISED) & FY
2024-25 (PROJECTED) .................................................................................................................. 107
5.2.1 TRUE UP OF AP SALES (FY 2022-23) ....................................................................................... 107
5.2.2 AP SALES ESTIMATION FOR FY 2023-24 AND FOR FY 2024-25 ..................................................... 109
5.3 ASSESSMENT OF ENERGY SALES FOR FY 2024-25 (OTHER CONSUMER CATEGORIES) ........................... 112
5.4 POWER PURCHASE QUANTUM AND COST .................................................................................. 115
5.5 INTERSTATE TRANSMISSION AND SLDC COST ............................................................................. 121
5.6 INTRASTATE TRANSMISSION AND SLDC COST ............................................................................. 121
5.7 INTERSTATE TRANSMISSION LOSSES AND INTRASTATE TRANSMISSION LOSSES ..................................... 122
5.8 ENERGY BALANCE ................................................................................................................ 122
5.9 OPERATION & MAINTENANCE EXPENSES (O&M)........................................................................ 125
5.9.1 EMPLOYEE EXPENSES ............................................................................................................ 128
5.9.2 REPAIR & MAINTENANCE (R&M) EXPENSES .............................................................................. 131
5.9.3 ADMINISTRATION & GENERAL (A&G) EXPENSES......................................................................... 132
5.10 APPROVED CAPITAL EXPENDITURE AND ADDITIONS TO GROSS FIXED ASSET ....................................... 133
5.11 INTEREST & FINANCE CHARGES: .............................................................................................. 134
5.11.1 INTEREST ON LONG TERM LOAN ................................................................................ 134
5.11.2 INTEREST ON ADVANCE CONSUMPTION DEPOSIT (ACD) ................................................. 138
5.11.3 INTEREST ON WORKING CAPITAL LOAN ....................................................................... 139
5.12 DEPRECIATION .................................................................................................................... 143
5.13 RETURN ON EQUITY.............................................................................................................. 146
5.14 BAD AND DOUBTFUL DEBTS ................................................................................................... 149
5.15 NON-TARIFF INCOME ........................................................................................................... 149
5.16 AGGREGATE REVENUE REQUIREMENT (ARR) ............................................................................. 150
5.17 REVENUE ESTIMATION .......................................................................................................... 152
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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

5.18 AP TUBEWELL SUBSIDY ......................................................................................................... 153

5.19 REVENUE SURPLUS / GAP FOR ARR YEAR FY 2024-25 ................................................................. 155
CHAPTER 6 ............................................................................................................................... 158

CAPITAL EXPENDITURE AND TECHNICAL PARAMETERS ................................................. 158

6.1 CAPITAL EXPENDITURE .......................................................................................................... 158

6.1.1 TRUE-UP OF CAPITAL EXPENDITURE FOR THE FY 2022-23 ............................................................. 158
6.1.2 REVIEW OF CAPITAL INVESTMENT PLAN IN PROGRESS FOR FY 2023-24 ............................................ 166
6.1.3 CAPITAL INVESTMENT PLAN (FY 2024-25) ................................................................................ 171
6.2 REVIEW OF TECHNICAL PARAMETERS ........................................................................................ 175
6.3 LOSS REDUCTION TRAJECTORY ................................................................................................ 178
6.4 DISTRIBUTION TRANSFORMERS (DTS) FAILURE RATE: ................................................................... 182
6.5 NON-REPLACEMENT OF ELECTRO-MECHANICAL METERS ................................................................ 185
6.6 IMPLEMENTATION OF SMART METERING PROJECTS IN HARYANA ..................................................... 185
6.7 PENDING ELECTRICITY CONNECTION / LOAD ................................................................................ 186
CHAPTER 7 ............................................................................................................................... 189

WHEELING CHARGES .................................................................................................... 189

7.1 WHEELING CHARGES ............................................................................................................ 189

7.2 CROSS-SUBSIDY SURCHARGE (CSS) .......................................................................................... 190
CHAPTER 8 ............................................................................................................................... 197

RENEWABLE PURCHASE OBLIGATION (RPO) .................................................................. 197

CHAPTER 9 ............................................................................................................................... 200

ADDITIONAL TARIFF ISSUES .......................................................................................... 200

9.1 TARIFF OF BULK SUPPLY (DOMESTIC) CATEGORY ......................................................................... 200

9.2 INCORPORATION OF TARIFF CLARIFICATION GIVEN BY HERC VIDE ORDER DATED 18.07.2023. .............. 201
9.3 TOD/TOU/NIGHT TIME CONCESSIONAL TARIFF .......................................................................... 201
9.4 CASH ACCEPTANCE LIMIT FOR THEFT PENALTY AND SURCHARGE WAIVER CASES. ................................ 202
CHAPTER 10 ............................................................................................................................. 204

TIME OF DAY/USE TARIFF ............................................................................................. 204

10.1 TOD / TOU TARIFF / NIGHT-TIME CONCESSIONAL TARIFF FOR FY 2024-25 ...................................... 204
CHAPTER 11 ............................................................................................................................. 208

DISTRIBUTION & RETAIL SUPPLY TARIFF ....................................................................... 208

ANNEXURE – A ......................................................................................................................... 209

SCHEDULE OF TARIFF AND CHARGES ................................................................................................. 209
ANNEXURE – B ......................................................................................................................... 214
DIRECTIVES ISSUED IN THE PRESENT ORDER. ........................................................................................ 214
ANNEXURE – C ......................................................................................................................... 218
DIRECTIVE COMPLIANCE STATUS OF ORDER DATED 15.02.2023- UHBVNL ............................................... 218

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 1

INTRODUCTION

1.1 Brief Background

The distribution licensees (Discoms) responsible for distribution and retail supply of electricity
to the consumers in Haryana are Uttar Haryana Bijli Vitran Nigam (UHBVNL) and Dakshin
Haryana Bijli Vitran Nigam (DHBVNL). The distribution and retail supply tariff determined by
the Commission in the Northern circles of Haryana i.e., licensed area of UHBVNL and Southern
circles of Haryana i.e., the licensed area DHBVNL are the same. Hence, the Commission has
considered it appropriate to dispose of their respective petition(s) for True-up of FY 2022-23,
Annual Performance Review (APR) Petition for FY 2023-24 and Aggregate Revenue
Requirement of FY 2024-25 vide the present common order.
It has been submitted that the Discoms have filed their respective petition(s) for Truing up of
ARR for FY 2022-23, Annual Performance Review for FY 2023-24 and Aggregate Revenue
Requirement for FY 2024-25 is in accordance with the provisions of the HERC MYT
Regulations, 2019 as amended from time to time.
That the Hon’ble Commission notified the MYT Regulations for the first ‘Control Period’, from
FY 2014-15 to FY 2016-17, on 5th December 2012 as HERC (Terms and Conditions for
Determination of Tariff for Generation, Transmission, Wheeling and Distribution & Retail
Supply under Multi Year Tariff Framework) Regulations, 2012 (hereafter MYT Regulation
2012), with subsequent amendments, the span of first MYT Period was extended to FY 2019-
20.
That on 31st October 2019, the Hon’ble Commission notified the MYT Regulations for the
second ‘Control Period’ from the FY 2020-21 to FY 2024-25 i.e., HERC (Terms and Conditions
for Determination of Tariff for Generation, Transmission, Wheeling and Distribution & Retail
Supply under Multi Year Tariff Framework) Regulations, 2019 (hereafter MYT Regulation
2019). The said Regulations were subsequently amended and the amended Regulations were
notified on 25th November, 2019 (1st amendment), 31st January, 2022 (2nd amendment) and
12th April, 2023 (3rd amendment).

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

1.2 Present Petition

That the licensee(s) have submitted that the instant petition is for determination of Truing up
of the ARR for the FY 2022-23, Annual Performance Review for the FY 2023-24 and Aggregate
Revenue Requirement and distribution retail supply tariff for the FY 2024-25 submitted by
UHBVNL and DHBVNL for approval of expenses of respective years and is prepared in
accordance with the provisions of the following Acts/Policies/Regulations: -
a) The Electricity Act 2003;
b) National Electricity Policy;
c) National Tariff Policy;
d) HERC (Terms and Conditions for Determination of Tariff for Wheeling and Distribution &
Retail Supply under Multi Year Tariff Framework) Regulations, 2019 as amended from
time to time;
e) HERC (Terms and conditions for grant of connectivity and open access for intra-State
transmission and distribution system) Regulations, 2012 and amendments thereof.
It has been averred that the Discoms have made their best efforts in compiling the
information for Truing up of ARR for FY 2022-23, Annual Performance Review for FY 2023-24
and Aggregate Revenue Requirement for FY 2024-25. It has been ensured that the
information submitted for ARR calculation of relevant year is free from material errors and is
consistent with relevant MYT Regulations. However, in case any deficiency is noticed in the
collation of information, the Discoms have prayed that the Hon’ble Commission may accept
the current petition and allow UHBVNL and DHBVNL to file additional submissions to rectify
any such deficiencies and to provide the requisite information as may be desired by the
Hon’ble Commission.

1.3 Principles of True up for FY 2022-23

That the Hon'ble Commission in exercise of the powers conferred upon it under Section 181
of the Electricity Act 2003 has notified the HERC (Terms and conditions for Determination of
Tariff for Generation, Transmission, Wheeling and Distribution & Retail Supply under Multi
Year Tariff framework) Regulations, 2019 for second control period from FY 2020-21 to FY
2024-25 on 31st October 2019, as amended the same from time to time.
That the HERC (Terms and conditions for Determination of Tariff for Generation,
Transmission, Wheeling and Distribution & Retail Supply under Multi Year Tariff framework)

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Regulations, 2019 has come into force from 1st April 2020 and shall remain effective till 31st
March 2025.
That, subsequently, the Hon’ble Commission has issued the 1st amendment of the HERC MYT
Regulations, 2019 on 25th November 2019 & 2nd amendment of the MYT Regulations, 2019
on 31st January 2019 and 3rd amendment of the MYT Regulations, 2019 on 12th April, 2023.
In line with the provisions of the MYT Regulation 2019, the Hon’ble Commission has published
the Tariff Order on Aggregate Revenue Requirement (ARR) & Retail Supply Tariff for FY 2022-
23 on 30.03.2022.
That Regulation 13 of the HERC MYT Regulations,2019 stipulates that truing up of ARR of the
previous year is to be carried out along with the mid-year performance review of each year
of the control period.
That truing up of ‘uncontrollable’ items and ‘controllable’ items (subjected to force majeure
conditions or variations attributable to uncontrollable factors) are adjusted appropriately in
the ARR’s of the ensuing year through tariff resetting. The relevant extract of the HERC MYT
Regulations, 2019 as cited by the petitioner(s) is reproduced below:
“13. TRUING-UP

13.1 Truing-up of the ARR of the previous year shall be carried out along with mid-year
performance review of each year of the control period only when the audited accounts
in respect of the year(s) under consideration is submitted along with the application.
In case audited accounts pertaining to the year, of which truing-up is to be undertaken,
are not available, the generating company or the licensee as the case may be, shall
submit the provisional account duly approved by the Board of Directors of the
company/licensee.

13.2 Truing-up of ‘uncontrollable’ items shall be carried out at the end of each year of the
control period through tariff resetting for the ensuing year and for controllable items
shall be done only on account of force majeure conditions and for variations
attributable to uncontrollable factors.

13.3 The Commission shall allow carrying costs for the trued–up amount (positive or
negative) at the interest rates specified in these Regulations by adjusting the interest
allowed on the working capital requirement for the relevant year of the control period.

Upon completion of the mid-year performance review and truing up in accordance with
these regulations, the Commission shall pass an order recording:

(a) The revised ARR for such financial year including approved modifications, if any;

(b) Holding cost for under/over recovered amount from the close of the relevant year
and upto the middle of the ensuing year of the control period whereupon the trued-
up amount has been adjusted by appropriate resetting of tariff in accordance with
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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

regulation 13.4, calculated as additional borrowing for working capital for that
period.

Provided that no carrying cost shall be allowed on account of delay in filing for true-
up due to unavailability of the audited accounts.

13.4 Over or under recoveries of trued-up amount in previous year(s) of the control period
shall be allowed to be adjusted in the ensuing year of the control period by appropriate
resetting of tariff. The unrecovered amount in the one control period shall be adjusted
in the subsequent control period.”

That in line with the above, True-up proposal for Aggregate Revenue Requirement for the FY
2022-23 has been worked out based on the actual expenses incurred by Discoms as per the
audited annual accounts of the FY 2022-23, has been submitted for approval of the Hon’ble
Commission.
As per Regulation 8.3.8 (titled as "Controllable and Uncontrollable Items of ARR"), and
Regulation 12 (titled as "Incentive and Penalty Framework") of the HERC MYT Regulations 2019,
the audited annual expenditures for the FY 2022-23 are trued up and the adjustment in the
ARR approved in Tariff Order dated 30th March 2022 will pass on along with the carrying cost/
Holding Cost into the ARR of the ensuing year i.e. FY 2024-25.
1.4 Summary of True up of FY 2022-23 (UHBVNL & DHBVNL)
Summary of expenses approved by the Hon’ble Commission vis-à-vis the actual expenses of
UHBVNL and DHBVNL for the FY 2022-23, as submitted by the Discoms, is as under:

True up of Expenses for FY 2022-23 of UHBVNL (Rs. Crore)

Sr. Particulars HERC Approved for Actual Difference
No FY22-23 (A) (Audited) (B-A)
(B)
1 Total Power Purchase Expense 10,977.94 15,951.59 4,973.65
1.1 Power Purchase Expense 9,018.20 13,668.06 4,649.86
1.2 Interstate transmission Charges 945.02 1,045.30 100.28
1.3 Intrastate transmission charges and SLDC 1,014.72 961.76
charges -52.96
1.4 Impact of sharing and gains of distribution - 276.46
losses 276.46
2 Operations and Maintenance Expenses 1,630.94 1,693.66 62.72
2.1 Employee Expense 859.41 857.53 -1.88
2.2 Administration & General Expense 112.85 199.15 86.30
2.3 Repair & Maintenance Expense 158.69 93.72 -64.97
2.4 Terminal Liability 500.00 543.25 43.25
3 Depreciation 414.53 374.60 -39.93
4 Interest & Finance Charges 336.16 410.21 74.05

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Sr. Particulars HERC Approved for Actual Difference

No FY22-23 (A) (Audited) (B-A)
(B)
Interest on WC loans including CC/OD limits 71.94 109.56 37.62
Interest on CAPEX loans 159.61 249.84 90.23
Interest on Consumer Security Deposit 69.71 61.64 -8.07
Guarantee Fees / Interest on other Bonds 34.90 24.98 -9.92
Less: Interest Capitalized -35.8) -35.82
5 Return on Equity Capital 250.33 238.31 -12.02
6 Other Expenses - 9.94 9.94
7 Total Expenditure 13,609.90 18,678.31 5,068.41
8 Less: Non-Tariff Income 221.56 116.27 -105.29
9 Net Aggregate Revenue Requirement 13,388.34 18,562.04 5,173.70

True Up of Expenses of DHBVNL for FY 2022-23 (Rs. Crore)

Sr. Particulars HERC Actual Difference
Approved (Audited)
(A) (B) (B-A)
1 Total Power purchase cost 15,110.94 22,760.95 7,705.08
1.1 Power Purchase Expenses 12,509.96 20,007.00 7,497.04
1.2 Interstate transmission charges 1,384.75 1,342.93 - 41.82
1.3 Intrastate transmission charges and SLDC charges 1,216.23 1,130.43 -85.80
1.4 Sharing of Gain/losses in Power Purchase Cost - 280.58
2 Operations and Maintenance Expenses 1,855.98 1,974.46 118.48
2.1 Employee Expense (Net of Capitalization) 1,072.88 984.89 - 87.99
2.2 Administration & General Expense (Net of 145.77 160.74 14.97
Capitalization)
2.3 Repair & Maintenance Expense 194.43 131.06 - 63.37
2.4 Terminal Liability 442.88 697.77 254.87
3 Depreciation 446.92 347.75 - 99.17
4 Total Interest & Finance Charges 427.02 362.61 - 123.40
5 Return on Equity Capital 236.75 211.69 59.62
6 Other Expenses (Debits & Prior period Expenses) - 17.67 17.67
7 Total Expenditure 18,077.61 25,675.13 7,678.28
8 Less: Non-Tariff Income 307.66 267.52 - 40.14
9 Net Aggregate Revenue Requirement 17,769.95 25,407.62 7,718.43
10 Total Revenue 16,528.41
10.1 Revenue from Interstate sales 499.55
10.2 Revenue from Intrastate sales / Sale of Power 16,028.86
11 Revenue Surplus/(Gap) -8,879.20
11.1 Less: Subsidy from Govt. of Haryana for AP 3,327.54
consumers
11.2 Less: Subsidy from Govt. of Haryana for others 269.64
12.3 Less: FSA Recovered -
12 Gap After AP Subsidy -5,282.03

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The net revenue gap for Haryana Discoms for the FY 2022-23, after considering the actual
expenditure as per the audited accounts for FY 2022-23 and revision of Agriculture Tube Well
Sales and RE Subsidy thereto, as proposed by the Discoms, is as under: -
Proposed Revenue Gap of Haryana (UHBVNL and DHBVNL) in True up for FY 2022-23 (Rs Crore)
Sr. Parameter HERC UHBVNL DHBVNL Haryana
no Approved
1 ARR of Discoms 31,158.29 18,562.04 25,407.62 43,969.66
2 Total Income of Discoms 30,735.58 14,807.50 20,125.58 34,933.08
a Sale of Power 24,684.89 11,536.80 16,028.86 27,565.66
b Interstate Sales - 325.27 499.55 824.82
d Subsidy 6,050.69 2,945.43 3,597.17 6,542.60
- AP Subsidy 6,050.69 2,722.54 3,327.54 6,050.08
- Domestic & Industry (C&D) subsidy 222.89 269.64 492.53
3 Revenue Surplus/(Gap) -422.71 -3,754.54 -5,282.03 -9,036.58
FSA - 3,127.49 4,544.84 7,672.33
Surplus on true-up of FY 2020-21 501.74 - - -
including holding cost
Net Revenue Surplus/(Gap) to be 79.03 -627.06 -737.19 -1,364.25
carried over to ARR year (FY 2024-25)

The Discoms have submitted that the net revenue gap of UHBVNL in the FY 2022-23 is
Rs. 3,754.55 Crore and DHBVNL is Rs. 5,282.03 Crore. As evident from the table above,
UHBVNL and DHBVNL have further considered Rs. 3,127.49 Crore and Rs. 4,554.84 Crore ly
respective on account of FSA Receivable (to be recovered in future years) and has accordingly
computed a combined revenue gap of Rs. 1364.25 Crore. In view of the above position, the
Discoms have prayed that the Commission may consider the combined revenue gap of
Rs. 1,364.25 Crore (Rs. 627.06 Crore of UHBVNL and Rs. 737.19 Crore of DHBVNL) as
submitted in table above for FY 2022-23 and the same may be allowed. The Discoms have
further requested that the ‘trued up’ amount may be allowed to be carried forward in the
ARR for the FY 2024-25. Further, the FSA receivable component to be recovered in future
years shall be accounted separately and shall be considered to be part of the Revenue for the
FY 2022-23 only.
In view of the above submissions, the distribution licensee(s) have prayed that this Hon’ble
Commission may consider and approve the net revenue gap as worked out in the table above
for the FY 2022-23 and the same may be carried forward in the ARR for the FY 2024-25.

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

1.5 Annual Performance Review for FY 2023-24 (APR UHBVNL & DHBVNL)
The revised estimate of UHBVNL and DHBVNL of the Aggregate Revenue Requirement for the
APR year, as submitted by the Discoms, is as follows: -
UHBVNL - Aggregate Revenue Requirement for FY 2023-24 (Rs. Crore)
HERC Revised
Sr. No Particulars Difference
Approved Estimates
1 Total Power Purchase Expense 13,990.30 14,807.95 817.65
1.1 Power Purchase Expense 11,931.85 12,984.26 1,052.41
1.2 Interstate transmission Charge 1,013.54 908.21 -105.33
1.3 Intrastate transmission charges and SLDC charges 1,044.91 915.49 -129.42
2 Operations and Maintenance Expenses 1,816.64 1,811.28 -5.36
2.1 Employee Expense 1,018.99 967.14 -51.85
2.2 Administration & General Expense 162.58 214.33 51.75
2.3 Repair & Maintenance Expense 185.07 179.81 -5.26
2.4 Terminal Liability 450.00 450.00 0.00
3 Depreciation 462.66 425.69 -36.97
4 Total Interest & Finance Charges 323.36 470.58 147.22
4.1 Interest on CAPEX loans 105.48 172.82 67.34
4.2 Interest on WC loans including CC/OD limits 116.39 150.28 33.89
4.3 Interest Cost on Consumer Security Deposit 66.59 112.58 45.99
4.4 Other Interest & Finance Charges 34.90 34.90 0.00
5 Return on Equity Capital 277.67 305.20 27.53
7 Total Expenditure 16,870.63 17,820.70 950.07
8 Less: Non-Tariff Income 278.43 278.43 0.00
9 Net Aggregate Revenue Requirement 16,592.20 17,542.27 950.07

DHBVNL - Aggregate Revenue Requirement for FY 2023-24 ( Rs. Crore)

APR
S.No. Particulars FY 2023-24
HERC Approved Projected Difference
1.0 Power Purchase Expenses 18,960.86 21,421.67 2,460.81
1.1 Power Purchase Cost 16,351.48 18,772.43 2,420.95
1.2 Transmission Charges 1,388.96 1,324.86 -64.10
1.3 Transmission Charges & SLDC 1,220.41 1,324.38 103.97
2.0 Operation & Maintenance Expenses 2,200.99 2,276.49 75.50
2.1 Employee Expenses (net) 1,271.32 1,175.85 -95.47
2.2 Administration & General Expenses (net)* 144.34 171.78 27.44
2.3 Repair & Maintenance Expenses 235.33 231.10 -4.23
2.4 Terminal Benefits 550.00 697.77 147.77
3.0 Depreciation 452.20 510.32 58.12
4.0 Interest & Finance Charges 473.99 605.20 131.21
4.1 Interest on Long Term Loan 154.59 165.51 10.92
4.2 Interest on Working Capital 186.95 179.81 -7.14
4.4 Interest on Consumer Security Deposit 100.06 185.45 85.39
4.5 Other Interest & Finance Charges 8.40 24.17 15.77
4.9 Guarantee Fee 24.00 50.26 26.26
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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

APR
S.No. Particulars FY 2023-24
HERC Approved Projected Difference
5 Return on Equity Capital 285.13 271.72 -13.41
6 Prior period expenses & other expenses 0 0 0
7 Other Debts, (including wealth tax) 0 0 0
8 Provisions for bad and doubtful debt 0 93.24 93.24
9 Aggregate Revenue Requirement 22,373.16 25,178.64 2805.48
10 Less: Non-Tariff Income 279.22 308.61 29.39
11 Net Aggregate Revenue Requirement 22,093.94 24,870.03 2776.09

The distribution licensee(s) have averred that, based on the revised estimates for Aggregate
Revenue Requirement of the Haryana Discoms and estimated revenue at the existing tariff,
details of revenue gap for the APR year is as under: -
UHBVNL and DHBVNL Revenue Gap for FY 2023-24 (Rs Crore)
Sr. no Particulars HERC Approved UHBVNL DHBVNL Haryana
Aggregate Revenue
1 38,686.15 17,542.27 24,870.03 42,412.30
Requirement
1.1 ARR-UH 16,592.20 17,542.27 17,542.27
1.2 ARR-DH 22,093.95 24,870.03 24,870.03
2 Revenue for Discoms 30,944.11 16,541.37 23,528.37 40,069.74
2.1 Sale of Power 30,944.11 12,545.78 18,648.25 31,194.03
2.2 Inter State Sales - 350.00 889.36 1,239.36
2.3 Revenue from FSA of FY 24 - 760.62 1,105.79 1,866.41
2.4 Subsidy from GoH 5,769.94 2,884.97 2,884.97 5,769.94
3 Revenue Surplus/(Gap) -1,972.10) -1,000.90 -1,341.66 -2,342.56
Revenue (Gap)/Surplus of FY
4 1844.87
2021-22*
5 Holding Cost @ 8.5% for 1.5 Year 235.22
Revenue Surplus/(Gap) to be
6 -262.47
carried over

In view of the above, the petitioner(s) have prayed that the revenue gap of Rs. 262.47 Crore
for the FY 2023-24 for APR year as per the detail presented above may be allowed and
adjusted appropriately in the relevant year.
1.6 Aggregate Revenue Requirement (ARR) for FY 2024-25

The distribution licensee(s) i.e. UHBVNL and DHBVNL have submitted that the ARR for the FY
2024-25 is based on the audited accounts of the FY 2022-23 and revised estimates for the FY
2023-24. The aggregate revenue requirement, as per the petition(s) filed by them, is
presented below:-

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

UHBVNL - Aggregate Revenue Requirement for FY 2024-25 (Rs Crore)

Sr. No Particulars FY 2024-25
1 Total Power Purchase Expense 14,218.48
1.1 Power Purchase Expense 12,293.34
1.2 Interstate transmission Charge 957.72
1.3 Intrastate transmission & SLDC 967.42
2 Operations and Maintenance Expense 2,146.60
2.1 Employee Expense 1,277.50
2.2 Administration & General Exp. 228.34
2.3 Repair & Maintenance Expense 190.75
2.4 Terminal Liability 450.00
3 Depreciation 453.94
4 Total Interest & Finance Charges 464.39
4.1 Interest on CAPEX loans 173.44
4.2 Interest on Working Capital incl. CC 130.87
4.3 Interest on Consumer Security Deposit 125.18
4.4 Other Interest and Finance charges 34.90
5 Return on Equity Capital 328.66
6 Total Expenditure 17,612.06
7 Less: Non-Tariff Income 278.43
8 Net Aggregate Revenue Requirement 17,333.63

DHBVNL Aggregate Revenue Requirement for FY 2024-25 (Rs. Crore)

ARR
S. No. Particulars FY 2024-25
Projected
1.0 Power Purchase Expenses 20,347.52
1.1 Power Purchase Cost 17,581.01
1.2 Transmission Charges 1,382.07
1.3 Transmission Charges & SLDC 1,384.44
2.0 Operation & Maintenance Expenses 2,476.48
2.1 Employee Expenses (net) 1,344.85
2.2 Administration & General Expenses (net) 183.57
2.3 Repair & Maintenance Expenses 250.29
2.4 Terminal Benefits 697.77
3.0 Depreciation 545.15
4.0 Interest & Finance Charges 623.73
4.1 Interest on Long Term Loan 197.19
4.2 Interest on Working Capital 152.75
4.3 Interest on Consumer Security Deposit 198.77
4.4 Other Interest & Finance Charges 25.01
4.5 Guarantee Fee 50.00
5 Return on Equity Capital 291.89
6 Provision for Bad & Doubtful Debt 100.55
7 Aggregate Revenue Requirement 24,385.33
8 Less: Non-Tariff Income 308.61
9 Net Aggregate Revenue Requirement 24,076.71

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Based on the estimates of the Aggregate Revenue Requirement of Haryana Discoms for the
FY 2024-25 and proposed revenue for sale of power, details of the estimated revenue gap at
the existing tariff(s) for the ARR year is as follows-
Combined Revenue (Gap)/Surplus for ARR year (Rs Crore)
(FY 2024-25)
Particulars UHBVNL DHBVNL Discoms
Aggregate Revenue Requirement 17,333.63 24076.71 41410.34
Revenue for Discoms 16,787.20 22994.32 39781.52
Sale of Power 13,902.23 20109.35 34011.58
Inter State Sales - - -
Subsidy from GoH 2,884.97 2,884.97 5769.94
Revenue Surplus/(Gap) -546.43 -1,082.40 -1,628.83
Revenue surplus / (Gap)for FY 2022-23 -1,364.25
Holding cost for 1.5 years @ 8.5% -173.94
Revenue Surplus/(Gap) to be carried over -3,167.02

That UHBVNL, in its petition, has submitted that the Aggregate Revenue Requirement for the
FY 2024-25 has been estimated based on the audited accounts for the FY 2022-23 and in
accordance with the HERC MYT Regulations, 2019. It has been submitted that for the True-up
year i.e. FY 2022-23, Haryana Discoms are in a revenue deficit of Rs.1,364.25 Cr., whereas
revenue deficit for APR year FY 2023-24 is Rs 2,342.56 Cr. However, after adjustment of
revenue surplus of Rs. 1,844.87 of FY 2021-22 along with carrying cost, the revenue deficit
gets reduced to Rs 262.47 Cr. The ARR year FY 2024-25 has a revenue deficit of Rs 1628.83
Crore, which will increase to Rs 3167.02 crore after the adjustment of revenue gap estimated
for the FY 2022-23 along with carrying cost.
That UHBVNL has submitted that the DISCOMs expect to recover some portion of the revenue
Gap due to the reduction of the distribution loss and purchase of power at comparatively
lower cost in the APR year and particularly in the ARR year. It has been submitted that the
Discoms are currently in the process of analyzing requirement of tariff modification, if any.
The same may please be allowed to be submitted as an additional submission at a later stage
if required.
DHBVNL has submitted that the DISCOMs expect to recover some portion of this Gap from
efficiency gain in the APR (FY 2023-24) and ARR (FY 2024-25) years. The remaining revenue
deficit will be covered through long-term/short-term loans.

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HERC Order on TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

1.7 Prayer
In view of the above submissions UHBVNL and DHBVNL have made identical prayers as
reproduced below: -
1. Accompanied filing of UHBVNL and DHBVNL for determination of Truing up of ARR for FY
2022-23, Annual Performance Review for FY 2023-24 and Aggregate Revenue
Requirement for FY 2024-25 may kindly be accepted and taken on record by the Hon’ble
Commission.
2. Current petition, filing of any additional / supplementary submissions during these
proceedings may kindly be allowed.
3. Proposed Return on Equity may be allowed.
4. Proposed sharing of gains and losses may be allowed.
5. Entire fixed charges of the long-term tied generating sources, having PPAs duly approved
by the Hon’ble Commission and the energy charges of the power purchase from these
sources and short-term sources as proposed in the filing, may kindly be allowed.
6. Truing-Up of ARR for FY 2022-23 along with the holding cost, revised estimate for the
expenses projected in Annual Performance Review for FY 2023-24, and Aggregate
Revenue Requirement for FY 2024-25 may kindly be allowed.
7. Inadvertent omissions/errors/shortcomings, addition / change / modification / alteration
in this filing, if any, may be allowed along with the further submissions as may be required
during the proceedings.
8. Pass the Order, as the Hon’ble Commission may deem fit and appropriate keeping in view
the facts and circumstances of the case submitted by the Petitioner.

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 2
PROCEDURAL ASPECTS

2.1 ARR Petition (UHBVNL & DHBVNL)

The Commission has taken on record the petition(s) filed by the distribution licensee(s) in
Haryana i.e. UHBVNL and DHBVNL and examined the same. The Commission, vide memo no.
3828/HERC/No.69 of 2023 dated 11.12.2023 (UHBVNL) and memo no. 3827/HERC/No.70 of 2023
dated 11.12.2023 (DHBVNL), sought a few clarifications /additional information from the
petitioners, which were provided by them. Further, a few additional information was sought
from the licensees vide memo no. 4296/HERC/No.69 of 2023 dated 16.01.2024 (UHBVNL) and
memo no. 4307/HERC/No.70 of 2023 dated 18.01.2024 (DHBVNL), to which replies were filed by
the Discoms.

2.2 Public Notice

The Discoms (UHBVNL & DHBVNL), in fulfillment of the statutory requirement under section
64(2) of the Electricity Act, 2003, issued Public Notice in two Newspapers i.e. UHBVNL published
the same in the Tribune (English) dated 02.12.2023 and Dainik Bhaskar (Hindi) dated 02.12.2023
and DHBVNL published the notice in the Tribune (English) dated 08.12.2023 and Dainik Tribune
(Hindi) dated 08.12.2023; informing the stakeholders/General Public regarding
petition/availability of documents on the website and inviting objections on the same.

To take the process forward, the Commission issued Public Notice in two newspapers, having
wide circulation in Haryana i.e., Dainik Bhaskar (Hindi) dated 14.12.2023 and The Tribune
(English) dated 13.12.2023. The said notice(s) inviting objections/ suggestions/comments from
the stakeholders/general public was also placed on the website of the Commission; the last date
for filing objections/comments was intimated as 29.12.2023. In response to the public notice,
the Commission received comments/suggestions/ objections from stakeholders, the details of
the objections / suggestions are listed in the paragraphs that follows.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

2.3 Objections filed by the Interveners, Discoms Reply thereto and Commission’s view.
In response to the public notice issued by the Discoms and subsequently by the Commission,
objections were received from various stakeholders. The objections filed by the interveners,
response of the Discoms and the Commission view thereto is as under:
2.3.1 M/s Faridabad Industries Association (FIA)
Comments/objections, vide letter ref. No./FIA/Letter/2023/114 dated 29.12.2023, received from
M/s Faridabad Industries Association, FIA House, Bata Chowk, N.I.T. Faridabad -121001 have
been reproduced as under: -
1. Issue of applicability of Wheeling Charges on Consumers connected to STU Network
1.1. An open access consumer who is connected at 66 kV and above shall be connected to
the STU network of Haryana state only and not to the distribution network, as such
consumer is not utilizing the distribution network and therefore, thereby it shall not
be liable to pay wheeling charges. HERC in the Distribution Licensee Tariff Order dated
15.02.2023 also appreciated the context defined “No” wheeling charges applicable on
the consumers procuring power at 66 kV and above network through open access.
1.2. HVPNL in line with the HERC Tariff Order, issued letter dated 29.03.2023 and informed
that wheeling charges for open access consumers and mentioned wheeling charges
for 66 kV and above voltage level as Rs. 0/ unit.
1.3. HVPNL further in reference to letter dated 29.03.2023 and memo received from the
Uttar Haryana Bijli Vidyut Nigam Ltd (UHBVNL) and Dakshin Haryana Bijli Vidyut Nigam
Ltd (DHBVNL) issued revised wheeling charges vide letter dated 18.05.2023, wherein
the wheeling charge for open access consumers connected at 66 kV and above voltage
level was revised from Rs. 0/ unit to Rs. 0.58/ unit.
1.4. The communication issued by the state distribution and transmission licensees as
referred in the HVPNL letter dated 18.05.2023 nowhere covers any order or letter or
communication issued by the Hon’ble Commission on the above discussed topic.
1.5. It seems that the HVPNL issued letter for levy of wheeling charges on open access
consumers connected to 66 kV and above voltage without any approval from the
Hon’ble Commission and in doing so has disregarded the Disco Tariff Order for FY
2023-24 issued by the HERC dated 15.02.2023.

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

1.6. The Commission is requested to assess the notifications in respect of the wheeling
charges for consumers connected at 66 kV and above and implement justified open
access charges as approved vide its Tariff order for Discom for FY 2023-24.
Reply filed by UHBVNL:
UHBVNL submitted that the definition of distribution system provided under section 2 (19) of
the Electricity Act 2003 which states that distribution system is the system of wires and
associated facilities between delivery points on the transmission lines or the generating station
and the point of connection to the consumers. Relevant excerpt of section 2 (19) is reproduced
here as under:
“Distribution system means the system of wires and associated facilities between the delivery
points on the transmission lines or the generating station connection and the point of connection
to the installation of the consumers,”
In view of the above quoted provision, any system of wires & associated facilities between the
transmission lines/generating station and point of connection to the consumer are the part of
the distribution system. Thus, system of wires and associated facilities for connections at 66 KV
& above voltage level between STU and point of connection at the consumer installation are the
part of distribution system and consumers connected at such voltage level are utilizing
distribution system for respective consumption through open access which also includes
transmission lines.
Further, the definition of Distribution System as provided in Electricity Rules, 2005 categorically
includes high pressure cables as follows:-
“ Distribution System.- The distribution system of a distribution licensee in terms of sub-section
(19) of section 2 of the Act shall also include electric line, sub-station and electrical plant that are
primarily maintained for the purpose of distributing electricity in the area of supply of such
distribution licensee notwithstanding that such line, substation or electrical plant are high
pressure cables or overhead lines or associated with such high pressure cables or overhead lines;
or used incidentally for the purposes of transmitting electricity for others.”
It is submitted that a similar situation has been dealt before the Hon’ble Commission in the case
of Northern Railways bearing no. PRO 66 of 2017 wherein the Hon’ble Commission had observed
as under:

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

“The Commission observes that the Electricity Rules, 2005 defines a distribution system as “4.
Distribution System.- The distribution system of a distribution licensee in terms of sub-section (19)
of section 2 of the Act shall also include electric line, sub-station and electrical plant that are
primarily maintained for the purpose of distributing electricity in the area of supply of such
distribution licensee notwithstanding that such line, substation or electrical plant are high
pressure cables or overhead lines or associated with such high pressure cables or overhead lines;
or used incidentally for the purposes of transmitting electricity for others”. Hence, it can be seen
from the ibid Rules that a distribution system also includes high pressure cables used for
transmitting electricity. The Commission after due deliberations is of the considered view that
NR, as a Medium-Term Open Access consumer, as per the ibid Rules is using, incidentally, the
distribution system of UHBVNL and DHBVNL. NR is not an embedded Open Access Consumer.
Hence, wheeling charges determined by the Commission are not recoverable from NR. However,
NR is liable to bear, besides intra state transmission loss, the distribution system network cost as
determined by the Commission for the relevant year i.e., Rs. 0.47 per Unit for FY 2020-21 in the
ARR/Tariff order of HVPNL (STU).”
Hence, levying of distribution system network cost on embedded open access consumers taking
supply at 66 KV or above is in line with the provisions of the Electricity Act 2003. It is also relevant
to mention that in any case, revenue from open access charges is accounted for the ARR as per
the provisions of the HERC MYT Regulations, 2019.
Thus, the contention of objector that it is connected with the network of the transmission
licensee and not using the network of the distribution licensees and therefore no such charge
shall be levied is incorrect.
The distribution system network cost @ Rs. 0.58/unit for Open Access Consumer connected at
66 kV and above voltage level is being charged as per HERC Order.
Reply filed by DHBVNL
1. DHBVNL submitted that the definition of distribution system provided under section 2 (19)
of the Electricity Act 2003 which states that distribution system is the system of wires and
associated facilities between delivery points on the transmission lines or the generating
station and the point of connection to the consumers. Relevant excerpt of section 2 (19) is
reproduced here as under:

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

"Distribution system means the system of wires and associated facilities between the
delivery points on the transmission lines or the generating station connection and the point
of connection to the installation of the consumers;"
2. In view of the above quoted provision, any system of wires & associated facilities between
the transmission lines, generating station and point of connection to the consumer are the
part of the distribution system. Thus, system of wires and associated facilities for connections
at 66 KV & above voltage level between STU and point of connection at the consumer
installation are the part of distribution system and consumers connected at such voltage level
are utilizing distribution system for respective consumption through open access which also
includes transmission lines.
3. Further, the definition of Distribution System as provided in Electricity Rules, 2005
categorically includes high pressure cables as follows: -
"4. Distribution System.- The distribution system of a distribution licensee in terms of sub-
section (19) of section 2 of the Act shall also include electric line, sub-station and electrical
plant that are primarily maintain. ed for the purpose of distributing electricity in the area
of supply of such distribution licensee notwithstanding that such line, substation or
electrical plant are high pressure cables or overhead lines or associated with such high-
pressure cables or overhead lines; or used incidentally for the purposes of transmitting
electricity for others"
4. lt is submitted that a similar situation has been dealt before the Hon’ble Commission in the
case of Northern Railways bearing no. PRO 66 of 2017 wherein the Hon'ble Commission had
observed as under:
"The Commission observes that the Electricity Rules, 2005 defines a distribution system as
"4. Distribution System.- The distribution system of a distribution licensee in terms of sub-
section (19) of section 2 of the Act shall also include electric line, sub-station and electrical
plant that are primarily maintained for the purpose of distributing electricity in the area
of supply of such distribution licensee notwithstanding that such line, substation or
electrical plant are high pressure cables or overhead lines or associated with such high
pressure cables or overhead lines; or used incidentally for the purposes of transmitting
electricity for others".

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Hence, it can be seen from the ibid Rules that a distribution system also includes high
pressure cables used for transmitting electricity. The Commission after due deliberations
is of the considered view that NR, as a Medium-Term Open Access consumer, as per the
ibid Rules is using, incidentally, the distribution system of UHBVNL and DHBVNL. NR is not
an embedded Open Access Consumer. Hence, wheeling charges determined by the
Commission are not recoverable from NR. However, NR is liable to bear, besides intra state
transmission loss, the distribution system network cost as determined by the Commission
for the relevant year i. e. Rs. 0.47 per Unit for FY 2020-21 in the ARR/Tariff order of HVPNL
(STU)."
5. Hence, levying of distribution system network cost on embedded open access consumers
taking supply at 66 KV or above is in line with the provisions of the Electricity Act 2003. It is
also relevant to mention that in any case, revenue from open access charges are accounted
for in the ARR as per the provisions of the HERC MYT Regulations, 2019.
6. Thus, the contention of objector that it is connected with the network of the transmission
licensee and not using the network of the distribution licensees and therefore no such charge
shall be levied is incorrect. Further, DHBVNL humbly submits that any order(s) may be passed
by the Hon'ble Commission regarding the change in Tariff for FY 2024-25 in the interest of
justice, as deemed fit.
Commission’s Observation:
The Commission has carefully examined the observations of the intervener on levy of
distribution system network cost on the open access consumers of the Discoms connected at
HT voltage and the reply filed by the Nigam(s). As also pointed out by the Nigam(s), the matter
has already been deliberated and decided by the Commission in the light of statute/rules cited
by the Nigam. Hence, no further discussion of this issue is required. The Commission reiterates
its findings on the issue as under: -
“The Commission observes that the Electricity Rules, 2005 defines a distribution system as “4. Distribution
System.- The distribution system of a distribution licensee in terms of sub-section (19) of section 2 of the
Act shall also include electric line, sub-station and electrical plant that are primarily maintained for the
purpose of distributing electricity in the area of supply of such distribution licensee notwithstanding that
such line, substation or electrical plant are high pressure cables or overhead lines or associated with such
high pressure cables or overhead lines; or used incidentally for the purposes of transmitting electricity for
others”. Hence, it can be seen from the ibid Rules that a distribution system also includes high pressure

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

cables used for transmitting electricity. The Commission after due deliberations is of the considered view
that NR, as a Medium-Term Open Access consumer, as per the ibid Rules is using, incidentally, the
distribution system of UHBVNL and DHBVNL. NR is not an embedded Open Access Consumer. Hence,
wheeling charges determined by the Commission are not recoverable from NR. However, NR is liable to
bear, besides intra state transmission loss, the distribution system network cost as determined by the
Commission for the relevant year i.e. Rs. 0.47 per Unit for FY 2020-21 in the ARR/Tariff order of HVPNL
(STU). Hence, levying of distribution system network cost on embedded open access consumers taking
supply at 66 KV or above is in line with the provisions of the Electricity Act 2003. It is also relevant to
mention that in any case, revenue from open access charges are accounted for in the ARR as per the
provisions of the HERC MYT Regulations, 2019”.
2. Exorbitant Open Access Charges compared to the neighbouring States.
2.1. The state has seen significant increase in the open access charges in the recent years.
2.2. A table depicting comparison of open access charges i.e. wheeling charge, CSS and
Additional Surcharge at 33 kV voltage level is depicted below.
NR states with open access charges at 33 kV level is as under: -
Comments on the Petition filed the Haryana Distribution Licensees (UHBVNL & DHBVNL) for
true-up for FY 2022-23, APR for FY 2023-24, ARR and Tariff for FY 2024-25

2.3. As can be observed from the table above, the state of Haryana figures among the states
with one of the highest charges.
2.4. As a result of the above, many industries are preferring to set up new units in the
neighbouring states i.e. UP, HP etc. This could ultimately result in revenue and
employment loss for the state of Haryana.
2.5. It is therefore requested that the charges may be rationalized to promote open access
in the state so that the industries can avail competitive power from alternate
mechanisms as well.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

FIA requested the Hon’ble Commission to kindly consider the above points while
finalizing the Order.
Reply by UHBVNL:
In this regard, it is submitted that Nigam is obligated to levy Tariff/Charges as approved by the
Hon’ble Commission from time to time.
Reply by DHBVNL:
In this regard, it is submitted that Nigam is obligated to levy Tariff/Charges as approved by the
Hon’ble Commission from time to time. Further, DHBVNL humbly submits that any order(s) may
be passed by the Hon’ble Commission in the interest of justice, as deemed fit.
Commission’s Observation:
On the issue of applicable wheeling charges, cross subsidy surcharge and Additional Surcharge
for Open Access Consumers, it needs to be noted that these charges flow from the ARR of the
Distribution Licensee(s). This would vary from one state to another, hence, the numbers cited
are not comparable. Nonetheless, while determining these charges in the present order, the
Commission will keep in mind the views of the intervener herein.
2.3.2 M/s Delhi Metro Rail Corporation Ltd.
Comments/objections, vide email dated 28.12.2023 and vide FTMS No 2770 and 2775 dated
28.12.2023, received from M/s Delhi Metro Rail Corporation Ltd., Metro Bhawan, 13 Fire Brigade
Lane, Barakhambha Road, New Delhi – 110001 is as under:
1. That this Hon’ble Commission vide public notice dated 29.11.2023 has invited
objections/suggestions on the petition(s) filed by HPGCL, HVPNL, UHBVNL and DHBVNL for
approval of True-up for the FY 2022-23, Annual Performance review for the FY 2023-24,
Aggregate Revenue Requirement for FY 2024-25.
2. That the instant objections have been filed inter-alia praying for reduction in Tariff due to
reduction in cost price in respect to objector namely Delhi Metro Rail Corporation Ltd. on
the following grounds: -
i. That the Applicant is engaged in the activity of providing Mass Rapid Transit System
for National Capital Region of Delhi including Gurugram, Faridabad and Bahadurgarh
and is performing a public utility function having social benefits. In connection with
the above activities, the Applicant requires electricity to run metro trains, ancillary

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

activities and operational requirements for which prayer regarding reduction in tariff
of DMRC is submitted (refer Para-3 below).
ii. That the Applicant/objector takes power supply from DHBVNL at 66 KV & UHBVNL at
132 KV voltage level for running of metro trains and supporting auxiliary services of
the stations such as Lifts, escalators, water supply, signalling, telecom, AFC, lightening
as well as commercial loads of PB/PD to serve the public/commuters at large.
iii. Comparison of Present Tariff and Tariff demanded by DISCOMs for FY 2024-25: -
Comparison of Previous and New tariff
Charges Tariff as per existing tariff order of Tariff demanded by DISCOMs
HERC for DMRC (FY 2023-24) for FY 2024-25 for DMRC
Unit tariff ₹6.45/kVAh
No Hike Demanded
Contract Demand charges ₹165/kVA/month
3. That reduction of DMRC’s Tariff as per the power purchase cost of DHBVNL & UHBVNL:
3.1. Comparison of Power purchase cost of DHBVNL and UHBVNL:
S.N. FY Power purchase cost for Power purchase Unit rate ₹/kVAh for DMRC
DHBVNL in ₹/kVAh cost for UHBVNL in (as per Tariff Order of
₹/kVAh HERC/Proposed in ARR
Petition)
1 2023-24 5.22 decrease 5.16 decrease 6.45
(Page-54 of APR) by 7.09 (Page-9 by 6.01
% of Exec %
Sum. of
2 2024-25 4.85 APR
4.85 No Hike demanded
(Page-84 of APR) (Page-9
of Exec
Sum. of
ARR

It has been averred that from the above table, w.r.t previous FY 2023-24, it is clear that the
rate of power purchase cost for FY 2024-25 is expected to decrease by 7.09 % for DHBVNL
and 6.01 % for UHBVNL. Hence, the intervener has requested that the Hon’ble Commission
may reduce the tariff for DMRC for the FY 2024-25 in proportion to the reduction in power
purchase cost of DISCOMs.
3.2. It has been further submitted that as per Clause 8.3 (1) of National Tariff Policy, 2016
titled as "Tariff design: Linkage of tariffs to cost of service" the retail supply tariff-shall
be determined based on the average cost of supply with a capping of +/-20%. The
relevant clause is reproduced as under:

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

“8.3 Tariff design: Linkage of tariffs to cost of service

For achieving the objective that the tariff progressively reflects the cost of supply
of electricity, the Appropriate Commission would notify a roadmap such that
tariffs are brought within +/-20% of the average cost of supply. The road map
would also have intermediate milestones, based on the approach of a gradual
reduction in cross subsidy.”
As the power purchase cost of DISCOMs are projected to reduce w.r.t previous Financial year,
certainly, the average cost of supply of both DISCOM would also decrease, hence, it has been
prayed that the Hon’ble Commission may reduce the tariff of DMRC in the same proportion.
UHBVNL Reply
In this regard, UHBVNL has submitted that the retail supply tariffs are determined by the Hon’ble
Commission based on the approved ARR in accordance with the principle of MYT Regulation,
2019 and its amendments from time to time. UHBVNL in the current petition, has submitted a
stand-alone gap of Rs. 627.06 Crore for True-up year FY 2022-23 and a projected revenue gap of
Rs. 546.43 Crore for ARR of FY 2024-25. It is also submitted that at Haryana level, Rs 1,628.83
Crore revenue gap has been projected in FY 2024-25. Furthermore, the objector should also have
taken note of the Discom’s submission in the petition that power purchase cost pertaining to
prior period and Change in Law have not been included in the projected power purchase cost for
FY 2024-25 due to the highly uncertain nature of these expenses. The actual power purchase
costs during the true-up of the relevant year will also include impact of these elements. Thus,
contention of objector regarding reduction in Power purchase cost and hence reduction in the
tariff in the same proportion is misplaced.
It is also to be noted that the revenue model for Discoms is purely on normative cost-plus basis
and there are other cost elements that generally increase over the years. The objector has failed
to consider the same. Given, there has been a minuscule tariff revision since last 5 years with
decreasing year-on-year agricultural subsidy, the revenue from sale of power is not sufficient to
cover the increasing cost components and hence the revenue gap.
DHBVNL Reply
In this regards DHBVNL has submitted that, the distribution and retail supply tariff are being
determined by the Hon'ble Commission based on the ARR determined as per principle of MYT
Regulation, 2019. DHBVNL in the current petition has submitted a stand-alone gap of Rs. 737.19

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

for True-up of FY 2022-23 Crore and Rs. 1,082.40 Crore for ARR of FY 2024-25. It is also to be
noted that the revenue model for Discoms is purely on normative cost-plus basis and there are
other cost elements apart from power purchase cost that generally increase over the years. The
objector has failed to consider the same. Given, there is almost minuscule tariff revision since
last 5 years with decreasing year-on-year agricultural subsidy, the revenue from sale of power is
not sufficient to cover the increasing cost components and hence the revenue gap. Thus,
contention of objector regarding reduction in Tariff on account of reduction in power purchase
is incorrect.
Further, DHBVNL humbly submits that any order(s) may be passed by the Hon'ble Commission
regarding the change in Tariff for FY 2024-25 in the interest of justice, as deemed fit.
3.3. In respect to the role of DMRC as a public utility having social benefits, the following
has been submitted by the intervener:
3.3.1. DMRC has contributed tremendously on the environment front by becoming the first
ever railway project in the world to claim carbon credits for regenerative Braking.
DMRC has also been certified by the United Nations (UN) as the first Metro Rail and
Rail Based system in the world to get carbon Credits for reducing Green House gas
Emissions as it has helped to reduce pollution levels in the city.
3.3.2. Since MRTS requirement is not there during the night, its working hours are restricted
from 0006 hrs to 2300 hrs only and DMRC does not carry any freight, therefore does
not have any option to make up for the shortfall in its revenue from passenger fare.
The above viewpoint has already been endorsed by Hon'ble commission in its tariff
order for FY 2010-11, FY 2011-12 & FY 2012-13.
3.3.3. Metro system decongests the Roads of the National Capital Territory Region and
provide environment friendly transportation system along with being energy efficient
and pollution free system, thereby benefiting the Nation.
3.3.4. It is pertinent to note that Energy Cost has a significant impact on DMRC's operating
cost and any increase in the energy cost may reflect in the increase in Metro fares
resulting in inconvenience to the general public and will conflict the principle of
providing good and affordable services to the public.
In view of the detailed submissions explained above, the Hon’ble commission is
requested to reduce the tariff for DMRC for FY 2024-25 for DMRC given its role as a

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

public utility having socials benefits and in proportion to the reduction in power
purchase cost of DISCOMs.
4. That no prejudice shall be caused to the DISCOMs in case the instant objection is allowed by
this Hon’ble Commission.
5. That the instant objections has been filed bona fide and in the interest of justice.
In view of the aforesaid facts and circumstances, it is most respectfully prayed that this
Hon’ble Commission in the public interest may be pleased to: -
i. To reduce the tariff of DMRC for the FY 2024-25 in respect to the role of DMRC as a public
utility having socials benefits and in proportion to the reduction in power purchase cost
of DISCOMs.
ii. Any such other order(s) be passed, in the interest of justice, as this Hon’ble Court deems
fit under the facts and circumstances of the case.
UHBVNL Reply
It is submitted that the Nigam is obligated to charge Tariff, as approved by the Hon’ble
Commission, from time to time. Any rebate in tariff is in the purview of the State Government
(sic), which in turn is obligated to compensate the Discoms as the utilities are working on
normative cost-plus model only claimed in accordance with the HERC MYT Regulations 2019.
DHBVNL Reply
In this regard, it is submitted that Nigam is obligated to charge Tariff as approved by the Hon'ble
Commission from time to time. Accordingly, DMRC are being charged respective tariff relevant
to their applicable consumer category & voltage level for use of electricity as per directions of
Hon'ble Commission from time to time. Further, DHBVNL humbly submits that any order(s) may
be passed by the Hon'ble Commission in the interest of justice, as deemed fit.
Commission’s Observations:
The Commission has taken note of the objections filed by DMRC seeking reduction in tariff and
Nigam(s) reply that Nigam is obligated to charge Tariff as approved by the Commission from
time to time. The Commission while taking the proceedings further will compute LT/HT CoS
and CS required and accordingly, realign tariff, if warranted. Hence, prior to working out the
ARR, revenue at the existing tariff including subsidy, revenue gap/surplus no observations can
be made. It may be noted that during the FY 2023-24 (est) and the FY 2024-25 (proj) the power
purchase cost including transmission charges paid to PGCIL and Haryana STU is expected to

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

witness significant rise. Further, the surge in demand, even during the months traditionally
considered off peak, is met / expected to be met from short / medium term sources including
Day Ahead / Real Term Market. All such sources, given the price discovered through
competitive bidding as well as those prevailing in the power exchanges, are by far expensive
as compared to the average cost of power tied up under long term Power Purchase
Agreements. Hence, it would be illogical to expect softening of the cost of delivered power.
2.3.3 Pankaj Bhalotia
Comments/objections vide letter dated 21.12.2023 with FTMS No 2769 dated 28.12.2023
received from Sh. Pankaj Bhalotia, Flat No: 1104, Gracious Tower, Imperial Estate, Sector: 82,
Faridabad – 121007, Haryana, India are as under:
1. Since both the Discoms of the State are running under profit, therefore, I should actually see
reduction in electricity tariff for FY 2024-2025 from its current level. Conceptually, both the
Discoms of the State works on a model of No profit and/or No loss and since they are running
under profit, they should pass such profits in the way of reduction in tariff, so that general
public can get benefits out of it.
UHBVNL Reply
UHBVNL submits that the True Up FY 2022-23 has been submitted based on the audited
accounts, while APR & ARR have been projected as per MYT Regulation, 2019. From the
submitted Petition, it can be observed that the UHBVNL has mentioned a stand-alone revenue
gap of Rs. 627.06 Crore for True-up year FY 2022-23 and a projected revenue gap of Rs. 546.43
Crore for ARR of FY 2024-25. It is also submitted that at Haryana level, Rs 1,628.83 Crore revenue
gap has been projected in FY 2024-25. Thus, the contention of the objector regarding reduction
in Tariff on account of profitability of state Discoms is incorrect.
DHBVNL Reply
ln this regards DHBVNL submits that, Retail Tariff are being determined by the Hon'ble
Commission based on the ARR determined as per principle of MYT Regulation, 2019. DHBVNL in
current petition has submitted a stand-alone gap of Rs. 737.19 for True-up of FY 2022-23 Crore
and Rs. 1,082.40 Crore for ARR of FY 2024-25. Thus, contention of objector regarding reduction
in Tariff on account of profitability of State Discoms is incorrect.
Further, DHBVNL humbly submits that any order(s) may be passed by the Hon'ble Commission
regarding the change in Tariff for FY 2024-25 in the interest of justice, as deemed fit.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Commission’s Observation:
The intervener has submitted that in view of the profits earned by Discoms, the tariff should
be reduced from its current level in the FY 2024-2025. The Commission has taken note of the
submissions of the intervener and observes that, as evident from the ‘retained earning’ of the
Discoms, appearing in their latest available audited accounts, is still negative. Further, for the
FY 2023-24 and the FY 2024-25 (projected), there exists revenue gap at the existing tariff, which
is further reduced by FSA to be recovered from the consumers. So, it implies that there is prima
facie no reduction as such, in the cost of power or the cost of delivered power to the consumers
by the Discoms.
2. The current levy of FSA @ 47 paisa per unit should not be charged from a domestic consumer,
whose monthly consumption is less than 200 units. However, when such domestic consumer
is a resident of a Group Housing society under Single Point Supply and has a Single Point
Connection, such FSA @ 47 paisa per unit is charged and recovered by DHBVNL and UHBVNL
in the form levy of FSA on total consumption of electricity and no concession/refund is given
by DHBVNL/UHBVNL for not to levy FSA @ 47 paisa per unit for a resident in a group housing
society under single point supply whose consumption is less than 200 units per month.
Requesting Commission to look into this and pass a suitable order in this regard.
UHBVNL Reply
In this regard, it is submitted that billing of Single Point Supply consumer is undertaken as per
the tariff schedule applicable for the current year. Clause 6.4: Billing of Single Point Supply of
HERC (Single Point Supply to Employers’ Colonies, Group Housing Societies and Residential or
Residential cum Commercial/ Commercial Complexes of Developers and Industrial Estates/ IT
parks/SEZ) Regulations, 2020 (hereinafter HERC Single Point Supply Regulations 2020). Any
modification of the existing regulation is in the purview of the Hon’ble Commission.
It is also submitted that it is the responsibility of the Employer/Developer/RWA/GHS/User
Association that the billing is to be done as per the relevant tariff orders and HERC regulations
for all domestic consumers. Any deviation from the applicable tariff order and regulation may be
intimated to the CGRF as per the HERC Single Point Supply Regulations 2020 as clearly stipulated
in regulations 5.3 reproduced as under:-
“The individual consumers in the GHS/Employer’s Colonies/Residential cum
Commercial/Commercial Complexes/ Shopping Malls/Industrial Estates/IT Park where Single

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Point Supply has been provided shall be treated at par with the consumers of the distribution
licensees and shall have the same rights and obligations as that of other consumers of distribution
licensee. These consumers shall also be covered under all other relevant Regulations of the
Commission including CGRF and Ombudsman Regulations, and tariff order issued by the
Commission, provided that in case of the provision of section 126, 135 and 138 of the Act the
distribution licensee shall be authorized to take necessary action as per these provisions of the
Act in coordination with such Employer’s Colony/GHS/ RWAs/Users Associations.”
DHBVNL Reply
ln this regard, it is submitted that the billing of Single Point Supply connections is undertaken as
per the tariff schedule applicable for current year and Clause 6.4: Billing of Single Point Supply of
HERC (Single Point Supply to Employers' Colonies, Group Housing Societies and Residential or
Residential cum Commercial/ Commercial Complexes of Developers and Industrial Estates/ IT
parks/SEZ) Regulations, 2020 (hereinafter HERC Single Point Supply Regulations 2020). Any
desired modification of the existing regulation is in the purview of the Hon'ble Commission.
It is also submitted that it is the responsibility of the Employer/Developer/RWA/GHS/User
Association that the billing is to be done as per the relevant tariff orders and HERC regulations
for all domestic consumers. Any deviation from the applicable tariff order and regulation may be
intimated to the CGRF as per the HERC Single Point Supply Regulations 2020 as clearly stipulated
in regulations 5.3 reproduced as under: -
"The individual consumers in the GHS/Employer's Colonies/Residential cum
Commercial/Commercial Complexes/ Shopping Malls/Industrial Estates/IT Park where Single
Point Supply has been provided shall be treated at par with the consumers of the distribution
licensees and shall have the same rights and obligations as that of other consumers of distribution
licensee. These consumers shall also be covered under all other relevant Regulations of the
Commission including CGRF and Ombudsman Regulations, and tariff order issued by the
Commission, provided that in case of the provision of section 126, 135 and 138 of the Act the
distribution licensee shall be authorized to take necessary action as per these provisions of the
Act in coordination with such Employer's Colony/GHS/RWAs/Users Associations."
Further, DHBVNL humbly submits that any order(s) may be passed by the Hon'ble Commission
regarding levy of FSA to Group Housing Society under single point supply in the interest of justice,
as deemed fit.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Commission’s observations:-
Regarding the objections on the levy of FSA and exempting the same for a DS consumer falling
in particular consumption slab or if such consumer is a resident of a Group Housing Society and
availing supply under Single Point Supply, who is subject to FSA irrespective of the units
consumed, is the decision of the State Government and the State Government take over the
FSA liability of such consumers under section 65 of the Electricity Act, which was not extended
to DS consumers under Single Point Supply. Hence, in the absence of subsidy commitment
w.r.t. FSA liability, the same will be levied in line with the provisions of the HERC MYT
Regulations in vogue. It is reiterated that FSA arises due to the fact that there is a difference
between the source wise cost of power purchase approved by the Commission including mix
of power and the actual power purchase cost at the Commission’s approved loss levels due to
several factors i.e. change in hydro-thermal mix, tariff revision by the appropriate Commission,
increase in fuel cost including transportation and short-term purchases to maintain demand-
supply balance. Hence, to keep cost and price (tariff) aligned and in line with the Electricity Act,
2003, the formula / methodology for working out FSA has been made part of the HERC MYT
Regulations, 2019 including its subsequent amendments. Having said so, FSA is formula driven,
it is up to the State Govtt. to provide subsidy support to a particular class / category of
consumers by taking over its FSA liability or not. In its absence, FSA is recoverable as per the
relevant Regulations. In the case of Bulk Supply (DS), the State Govtt. has not committed any
subsidy support by taking over the FSA liability, hence, the FSA is leviable.
3. Levy of Fixed Charges for Bulk Supply (Domestic) Categories Consumers
4. The CGRF, DHBVNL, Gurugram had passed an order in this regard which describing the
method and procedure to follow to calculate and charge the Fixed Charges from Bulk Supply
(Domestic) Categories Consumers on a monthly basis. However, DHBVNL and UHBVNL both
have failed in this regard to implement the decision of CGRF, DHBVNL, Gurugram. Therefore,
requesting the commission to consider the judgement of CGRF and get it implemented by
DHBVNL and UHBVNL for correct way of levying fixed charges on Bulk Supply (Domestic)
Categories Consumers.
a) In Appeal No. DH / CGRF / 2966 / 2020 between Sh. B. K. Aggarwal Vs. SDO (OP) Sohna
Road, DHBVNL, Gurugram, the CGRF DHBVNL Gurugram vide S. No. 5 of its order dated:
10.02.2021 have already held and gave its direction in this regard to DHBVNL that to not

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to round off the MDI each month and charge it strictly as per Tariff Order issued by HERC
each year (see below extract of S. No. 5 of the Order of CGRF), however till date, DHBVNL
is still rounding off the MDI each month to calculate Fixed Charges.
“5. Forum observes that neither there is any need for DHBVNL to round off month wise
recorded MDI nor to apply the formula MDI x 12x 100 /365. Charging of Fixed Chares is
very simple by just multiplying the recorded MDI with the Fixed charges per KW per month
as defined in the tariff order.”
b) This very CGRF DHBVNL again, in Appeal No. DH / CGRF / 3681 / 2021 between Sh. B. K.
Aggarwal Vs. SDO (OP) Sohna Road, DHBVNL, Gurugram, vide S. No. 2 of its order dated:
06.11.2022 held that DHBVNL should immediately stop unnecessary formula to calculate
fixed charges and gave further direction that it should be calculated simply by multiplying
MDI with the rate and any excess charges calculated in this regard in past by DHBVNL
should be refunded with interest to the complainant.
“2. Calculation of fixed charges on the basis of recorded MDI by using an unnecessary
formula should immediately stop and that the fixed charges should be calculated simply
by multiplying MDI with the rate. Any excess fixed charges, if levied previously on this
account, should be refunded with interest in the next billing cycle."
DHBVNL Reply
DHBVNL humbly submits that, Tariff for Bulk Supply Domestic is being charged as per Hon'ble
HERC Tariff Order for the relevant year. Any order(s) may be passed by the Hon'ble Commission
in the interest of justice, as deemed fit.
Commission’s observations:
The Commission has perused the objections and observes that the Tariff for Bulk Supply (DS)
is governed by the terms and conditions of the Single Point Supply Regulations in vogue. Hence,
levy of tariff including Fixed charge ought to be accordingly levied. DHBVNL, as also pointed
out in the State Advisory Committee meeting held on 9th February, 2024; must implement the
order of CGRF/Ombudsman with immediate effect. As in the case of UHBVNL, the Whole Time
Director (WTD) must also review the compliance monthly and take appropriate action for any
complacency in this regard.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

5. Surcharge for delayed payment of Electricity Bills

The intervener has averred that in terms of Regulation 6.6 of the HERC (Electricity Supply Code)
Regulations, 2014, the Commission is requested to declare the delayed payment Surcharge rate
of electricity bills while announcing the Tariff Structure for FY 2024-2025.
Regulation 6.6 of the HERC (Electricity Supply Code) Regulations, 2014 says that “In case the
consumers do not pay the bill by the due date mentioned in the bill, surcharge for delayed
payment of bill shall apply as per tariff orders issued by the commission from time to time”.
Therefore, to remove ambiguity in this regard, requesting the Commission to declare the rate of
surcharge for delayed payment of bills for various categories of consumers while announcing the
Tariff Order for FY 2024 – 2025.
UHBVNL Reply
As per the clarification issued by HERC vide memo no. HERC/D(Tariff)/ARR-10-11/1974-78 dated
04.10.2010, it has already been notified the surcharge on unpaid bills be levied i.e.
• 3% bi- monthly on unpaid amount of energy bills in case of domestic and non-domestic
consumers.
• 1.5% monthly on unpaid amount of energy bills in case of all other categories of consumers.
These instructions had been circulated by UHBVNL on Sales Circular Number U-30/2010 dated
05.10.2010.
DHBVNL Reply
As per the clarification issued by HERC vide memo no. HERC/D(Tariff)/ARR-10-11/1974-78 dated
04.10.2010, it has already been notified the surcharge on unpaid bills be levied i.e.
a. 3% bi-monthly on unpaid amount of energy bills in case of domestic and non-domestic
consumers.
b. 1.5% monthly on unpaid amount of energy bills in case of all other categories of consumers.
DHBVNL humbly submits that, for further clarification in matter any order(s) may be passed by
the Hon'ble Commission in the interest of justice, as deemed fit.
Commission’s observations:
The issue of the delayed payment surcharge has been addressed by the Commission as brought
out in the reply filed by the Discoms. Hence, no further deliberations on this issue is required.
6. Rebate/discount in Tariff for consumers availing supply through Independent Feeder for
bearing of Distribution and Transmission Losses.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The Commission while deciding tariff for FY 2017-18 in Appeal No. HERC/PRO-39 of 2016 and
HERC/PRO-40 of 2016, did acknowledged my suggestions/ objections to have separate tariff
structure for Independent Feeder, but so far nothing has been done in this regard neither by the
Commission nor by the Discoms of the State to have separate tariff structure for an Independent
Feeder Consumer.
A consumer, availing electricity through Independent Feeder, get billed as per the meter placed
at powerhouse and not as per meter installed at consumer’s premise and accordingly bear all
the feeder losses as well as distribution and transmission losses, whereas in case of all other
consumers the feeder and distribution/transmission loss is bear by the Discom of the State,
So there is discrimination with regard to tariff which an Independent Feeder Consumer pays, the
same tariff is also paid by a consumer who is not under Independent Feeder and the Commission
would like to remove this discrimination by allowing some Discount/Rebate in tariff for consumer
that avails supply of electricity through Independent Feeder because of reason as explained that
Independent Feeder Consumer bears the Feeder as well as distribution and transmission losses,
which a consumer who is not under Independent Feeder does not bear and does not pay. May
be a rebate of 4% for supply upto 11kV and 5% for supply at higher voltage should be allowed to
an Independent Feeder Consumer towards Feeder and Distribution and Transmission Losses.
UHBVNL Reply
UHBVNL humbly submits that the objector is under misconception that other consumers, not
connected on independent feeder, do not bear the burden of transmission and distribution
losses. It is to be noted that as the revenue model for Discoms is purely on normative cost-plus
basis, the approved losses are already included in the revenue and ARR calculation and
accordingly the tariffs are charged from each and every consumer as per the tariff schedule
approved by the Hon’ble Commission.
It is also submitted that the 11 KV independent feeder losses are minuscule and Discoms bill the
consumer, who has requested to be fed through independent feeder, strictly as per clause 4.8.2
of HERC Duty to Supply Regulations 2016 and respective tariff relevant to their applicable
consumer category & voltage level. Setting the tariff schedule is in the purview of the Hon’ble
Commission. In case the objector desires any modification of the existing regulation, it may kindly
approach the Hon’ble Commission for the same.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL Reply
DHBVNL humbly submits that, the consumers on independent feeder are being charged
respective tariff relevant to their applicable consumer category & voltage level for use of
electricity. So, there is no need of separate tariff for consumers on independent feeder.
Commission’s observations:
The Commission has considered the submissions of intervener and reply filed in the matter. It
is noted that there is multiplicity of independent feeder, since losses are to be borne by the
consumers and the same will vary depending on the length and other technical characteristics,
hence, having a plethora of rates, in the considered view of the Commission, is not feasible.
Needless to add that a electricity consumer opt for taking supply through an independent
feeder primarily because of his concern for quality and continuity of supply including
minimising the possibilities of ‘outages’ in supply of power. Hence, the issue is not so much of
tariff but reliability of supply.
7. No Corresponding Reduction in Tariff for Bulk Supply (Domestic) when Domestic Supply (DS)
supply category tariff was reduced by the Commission during Tariff announcement on June
01, 2020 for FY 2020-2021 and in Subsequent Years.
(a) While announcing tariff on June 1, 2020, the Commission reduced the tariff for a Domestic
Supply (DS) Category consumer under Category- I and II, but there was no corresponding
reduction made in tariff for bulk supply domestic category. The Tariff for bulk supply
domestic category kept at same structure as it was in previous year.
(b) By not reducing the tariff for bulk supply domestic category, the residents of a Group
Housing Society were not benefited for the reduction in Tariff made under Domestic Supply
(DS) Category. Basically, the reduction in Tariff made under Domestic Supply (DS) Category
under I and II has resulted into lower tariff for individual consumption inside the flat, but
at the same time, it has resulted into increase in the share in common area electricity (CAE).
So there is no impact on the pocket of a Resident of Group Housing Society under Single
Point Supply by reducing the Tariff for DS Category, because such reduction has increased
the share in common area electricity (CAE) and thus no benefit for reduction in tariff for
domestic supply category if there is corresponding reduction in Tariff for Bulk Supply
Domestic category. Illustration for better understanding is as under:

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Say the monthly electricity bill of the housing society for November month was Rs. 10 Lakhs
and out of that Rs. 10 lakhs bill, 50% (Rs. 5 Lakhs was for individual consumption inside the
flat on which DS tariff was applicable) and balance 50% was for common area use. Now,
after the Tariff Order dated: June 01, 2020, and due to reduced DS Category Tariff the share
of individual consumption has got reduced to 40% from earlier 50% and consequently the
common area share got increased to 60% from earlier 50%, whereas common area share
should have remained same to 50%. The Question is why reduction in DS category Tariff
would result into increase in share of common area electricity for a resident of a group
housing society?
(c) That why the reduction in Domestic Supply (DS) Tariff will increase the share of Common
Area Electricity (CAE) for a resident of a group housing society having single point supply
and accordingly a reduction in tariff for Bulk Supply (Domestic) is required to compensate
the hardship on the Resident of a Group Housing Society under Option – 1 for increase into
share in Common Area Electricity (CAE) due to reduction in Tariff structure for DS category
consumers.
UHBVNL Reply
It is submitted that billing of individual consumers of a GHS being fed through single point supply
is in the purview of the RWA/Builder and not that of Discoms, Hence, the objector may kindly
approach them for any clarification regarding increase in Common Area Charges.
Furthermore, Discoms bill the consumers as per the respective tariff applicable to the consumer
in accordance with the consumer-categories mentioned in the tariff schedule approved by the
Hon’ble Commission for relevant year. Hence, tariff setting is in the purview of the Hon’ble
Commission and not that of Discoms.
It is also submitted that it is the responsibility of the Employer/Developer/RWA/GHS/User
Association that the billing is to be done as per the relevant tariff orders and HERC regulations.
Any deviation from the applicable tariff order and regulation may be intimated to the CGRF as
per the HERC Single Point Supply Regulations 2020 as clearly stipulated in regulations 5.3
reproduced as under:-
“The individual consumers in the GHS/Employer’s Colonies/Residential cum
Commercial/Commercial Complexes/ Shopping Malls/Industrial Estates/IT Park where Single
Point Supply has been provided, shall be treated at par with the consumers of the distribution

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

licensees and shall have the same rights and obligations as that of other consumers of
distribution licensee. These consumers shall also be covered under all other relevant Regulations
of the Commission including CGRF and Ombudsman Regulations, and tariff order issued by the
Commission, provided that in case of the provision of section 126, 135 and 138 of the Act the
distribution licensee shall be authorized to take necessary action as per these provisions of the
Act in coordination with such Employer’s Colony/GHS/ RWAs/Users Associations.”
DHBVNL Reply
DHBVNL humbly submits that, Tariff for Bulk Supply Domestic is being charged as per Hon'ble
HERC Tariff Order for the relevant year. Any order(s) may be passed by the Hon'ble Commission
in the interest of justice, as deemed fit.
Commission’s observations:
The intervener needs to note that there are two distinct segments to the Bulk (DS) Tariff.
Firstly, electricity supplied by the Distribution licensee of the area and secondly, from that said
Single Point, electricity supplied to the individual premises and common area etc. In the case
of former, the tariff on an annual basis, including a fixed charge based on the recorded demand
at the meter installed at a ‘Single Point’ is determined by the Commission. While metering,
billing etc. in the second segment is the responsibility of the Employer/RWA/GHS/Developer,
as the case may be subject to the terms of Single Point Supply Regulations in vogue. Hence,
tariff beyond the supply is not within the scope of the present proceedings and Regulations
can only be taken up for judicial review.
8. No Subsidy, Discount, Rebate, Offer, Cashback is Available to a Resident of a Group Housing
Society under Single Point Supply under Option – 1.
(a) We all know that for all purposes, a Resident of a group housing society under bulk supply
domestic is a domestic category consumer and it has a same right and obligations which
a consumer under domestic supply category has and accordingly entitled to receive all
types of subsidies, discount, rebate, Offer, Cashback etc as available to a domestic supply
(DS) category consumer.
(b) The Commission did acknowledge this while deciding Tariff last year and accordingly
reduced the Fixed Charges from Rs. 100/kW to Rs. 80/kW by providing some relief in this
regard but the reduction of Rs. 20/kW in fixed charges is actually nothing by comparing
it to amount of subsidy, rebate, discount, Offer, Cashback is available to a Domestic

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Category Consumer and accordingly a better approach should be made by the

Commission in providing relief in Tariff to cover the amount of subsidy, discount, rebate,
Offer, Cashback etc. for a resident of a Group Housing Society as being available to a
Domestic Category Consumer.

UHBVNL Reply
It is submitted that any discount, rebate, or subsidy is under the purview of the State
Government. As per Section 65 of the Electricity Act, 2003, if the State Govt. gives a rebate or
exemption to category/categories of consumer on the tariff determined by the Commission,
discounted tariff to that extent is charged by the Discoms to those consumers from time to time.
However, there is currently no subsidy, rebate, offer, or cashback available on HERC approved
tariff applicable for domestic consumers and the tariff schedule is implemented as approved by
the Hon’ble Commission for the relevant year.
Furthermore, many of the contentions submitted by the petitioner have already been addressed
in the PRO-48 of 2018 in which the Commission did not find any merit in the similar submissions
and disposed of the matter vide order dated 21.02.2019.
DHBVNL Reply
DHBVNL humbly submits that, as per Section 65 of the Electricity Act, 2003, if the State Govt.
gives a rebate or exemption to category/categories of consumer on the tariff determined by the
Commission, subsidy to that extent has to be given by the State Government to the Discoms from
time to time.
Further, DHBVNL humbly submits that, Tariff for Bulk Supply Domestic is being charged as per
Hon'ble HERC Tariff Order for the relevant year. Any order(s) may be passed by the Hon'ble
Commission in the interest of justice, as deemed fit.
Commission’s Observation:
The Commission tends to agree with the reply filed by the Discoms. The intervener needs to
note that rebate in terms of energy recorded at the single point has been provided to
established parity between the two sets of DS consumers.
2.3.4 Amina Chawla, GMDA, Gurugram

A. Comments/objections vide email dated 01.01.2024 enclosed with letter memo no.
GMDA/Electrical/2024/01 dated 01.01.2024, FTMS No 12 dated 01.01.2024 has been

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received from Smt. Amina Chawla, Executive Engineer (Electrical) GMDA, Gurugram is
reproduced as under:
That currently, all Sewage Treatment Plants (STPs), Water Treatment Plants (WTPs) under
the jurisdiction of Gurugram Metropolitan Development Authority (GMDA) is not covered
under any particular Tariff Category specified by HERC. However, it is submitted that these
plants perform similar function of serving public at large like other Public Utilities i.e DMRC,
Railways do. It is pertinent to state that such Public Utilities are covered under “HT Supply
Tarif” category of HERC i.e Rs 6.25/kVAh. The same quantum of Tariff specified by Delhi
Electricity Regulatory Commission for various such consumers including Delhi Jal Board,
which performs the same function of pumping and sewage, is under the Category of “Public
Utilities” being charge @Rs. 6.25/kVAh (as per Sr. No.6 of Tariff Schedule for FY 2021-22 of
latest applicable DERC Tariff Order FY 2021-22). Relevant Pages of DERC Tarif Schedule is
annexed herewith for your kind reference.
In view of the above, it is proposed that all WTPs/STPs of Haryana State to be covered
specifically under HT Supply Tariff Category (like in DMRC or Railway Traction load) as these
are also serving the public at large.
B. Comments and objection vide email dated 01.01.2024 vide letter Memo No. MCG/EE-
Elect/2024/35 dated 01.01.2024 FTMS No. 11 dated 01.01.2024 from Smt. Amina Chawla,
Executive Engineer (Electrical), GMDA, Gurugram is as under:
That currently, all Public Street Lighting Load of Public Utilities like MCG, PWD B&R, HSIIDC, HSVP,
GMDA is not covered under any particular Tarif Category specified by HERC. However, it is
submitted that this consumer category of load performs similar function of serving public at large
like other Public Utilities i.e DMRC, Railway do. It is pertinent to State that such Public Utilities
are covered under “HT Supply Tariff” category of HERC i.e 6.25/ kVAh. The same quantum of
Tariff specified by Delhi Electricity Regulatory Commission for various such consumers including
“Public Lighting, which performs the same function, is under the Category of “Public Utilities”
being charge @Rs. 6.25/kVAh (as per Sr. No.6 of Tariff Schedule for FY 2021-22 of latest
applicable DERC Tariff Order FY 2021-22). Relevant Pages of DERC Tarif Schedule is annexed
herewith for your kind reference.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

In view of the above, it is proposed that all Public Street Lighting consumer including MCG, PWD
B&R, HSIIDC, HSVP, GMDA of Haryana State to be covered specifically under HT Supply Tariff
Category (like in DMRC or Railway Traction load) as these are also serving the public at large
DHBVNL Reply
DHBVNL humbly submits that, the public utilities are being charged respective tariff relevant to
their applicable consumer category & voltage level for use of electricity as per directions of
Hon’ble Commission from time to time. Further, DHBVNL humbly submits that any order(s) may
be passed by the Hon'ble Commission regarding the change in Tariff for the FY 2024-25 in the
interest of justice, as deemed fit.
Commission’s Observations
The Commission has taken note of the suggestions of the intervener and shall consider the
same subject to the proposal being feasible and revenue neutral.
2.3.5 B.K. Aggarwal

Sh. Aggarwal, vide his email dated 29.12.2023 submitted objections/comments in respect of
Billing, FSA, TDS, F.C. (Fixed Charges), Security Interest / ACD and LPS (Late Payment Surcharge)
on retailers under Chapter 9 of tariff as per Section 62(1) d, and the Electricity Supply Code
framed under Section 50, Unified Billing, Revenue Surplus/ (Gap) on the basis of stakeholder on
practical aspect with experience. More importantly DHBVNL Submissions in ARR for Tariff 2024-
2025:
Clause 1.40: SURCHARGE LEVIED ON DELAYED PAYMENT: -
Delayed payment charges are recognized, on ground of prudence, as and
when accounted for as income from surcharge. On this basis a sum of Rs.
28950.24 lakhs has been accounted for as income from surcharge. Under
Prayer: Chapter 6: By DHBVNL ANNUAL STATEMENT OF ACCOUNTS
FINANCIAL YEAR 2022-23.
A. It is important to mention there are mainly two types of Categories of Consumer i.e. one
for rattlers (sic.) whereas consumers like ours are covered under Category in chapter 9 of
tariff for retailers r/w section 62 (1) d of Act 2003 vis-à-vis Consumers as prosumer as per
the Direction/Guide Lines as per NOTIFICATION Gazette of India Extraordinary, New
Delhi, the 31st December, 2020: G.S.R. 818(E).----: (11). Consumer as prosumer:-

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B. That Consumer B.K. Aggarwal D-503, Flat Owner Cum Resident out of 608 Flats/ Dwelling
Units having Electricity Connection at Single Point Supply BSDS at 11 KV with DHBVNL
bearing A/c No 6307821000.
C. That RWA in the name of PVCCA “Park View City Condominium Association” is the
successor of Developer PVAPL “Park View Apartments Pvt Ltd” on 14.12.2011. That we
are having agreement with DHBVNL to realize charges as per HERC Approved Regulations
& HERC tariff issued from time-to-time inter-alia Statutory Agreement. Important: That
any regulation if modified / Amended or repealed as per HERC orders & similarly HERC
time to time are replacing/ tariff normally once in Financial Year and applicable Schedule
of Charges of Consumers Like Ours are issued in the category of retailers under Chapter
9 of tariff.
D. That as per Clause 6.6 of HERC Regulation No 29/2014 of dated 8th Jan, 2014 and is being
reproduced again for ready reference “6.6 Surcharge for delayed payment of bills In case
the consumers do not pay the bill by the due date mentioned in the bill, surcharge for
delayed payment of bill shall apply as per tariff orders issued by the commission from time
to time.” Respondent DHBVNL and its Officers are willfully acting in violations of the
above statutory provisions. Perusal of the bills issued by the DHBVNL clearly shows that
appellant has been charged @ 18% per annum which is contrary to HERC Order. HERC
has not decided late payment surcharge @18% per annum, rather no late payment
surcharge has been determined by the HERC. If a consumer fails to make payment of the
bill then DHBVNL can take recourse in accordance with law but it is not free to levy late
payment surcharge as per its wish and whims.
E. That as per Hon’ble Supreme Court of India Civil Appellate Jurisdiction CIVIL APPEAL NO.
1672 OF 2020 (Arising out of SLP (Civil) No. 5190 of 2019) and hereinafter, shall be called
case No 1672 of 2020. Mistake regarding wrong LPS charges by Applicant in E.O. Appeal
No 1/2023 was realized in Oct, 2022 and stake holder for comments in the DHBVNL ARR
published on DHBVNL Website (For the first time) and not adhered to SDO (OP) message
about the Surcharge Waiver Scheme vide DHBVNL Sales Circular D-24/2022 dated
31.08.2022 for opting the Surcharge Waiver Scheme. “The illegal action by SDO (OP) by
disconnecting our supply on 15/11/2022 confirms the condition of SDO (OP) M., Dharam
Singh by willfully disobeying the approved HERC Regulations and against Section 56 of

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Electricity Act, 2003 and clarity by Hon’ble Supreme Court Order of 18.02.2020 the Copy
of the Said order is with DHBVNL & HERC as handed over on 13.12.2023.” The worst part
on the part of DHBVNL Every Bill issued monthly to us from 2015 in respect of F.C. “Fixed
Charges” till date is wrong “known to everyone”. However, wrong LPS charges “Stake
Holder knowing” came to the knowledge in Oct, 2022. But licensee/’s are in fact by
continuously issuing wrong bills and if not paid these bills LPS @ 18% inter-alia DHBVNL
action is against the consumer interest. Regarding wrong Bills it is being reproduced for
ready reference “That as per Clause No 8.3 of HERC Regulation No HERC/50/2020 dated
24th Apr, 2020 and herein after shall be called Regulation 50/2020 “Licensee shall ensure
that at any point of time the percentage of bills requiring modifications following
complaints to the total number of bills issued does not exceed 0.1%”.
Provided that in case a wrong electricity bill for sale of power is issued by the
licensee, the same shall be corrected and a revised bill shall be issued to the consumer
by the SDO in-charge within 3 days. Further, the adjustment of any amount on account
of correction made in the bill shall be reflected in the next bill. In case the future bill (the
second bill after the correction of the wrong bill), is found to be wrong the SDO in-charge
shall be liable to pay a penalty of Rs 500/- per default. Provided further in case such
default is found to occur thrice, the defaulting officer shall be preceded under the
Punishment and Appeal Rules for this act of omission.” Respondent SDO despite
directions of Electricity Ombudsman for overhauling the bills of appellant as well as
direction by CGRF vide order dated 06.11.2022, no heed is being paid by the respondent
SDO to issue the correct bills, hence in terms of the above regulations, direction be issued
for initiating departmental inquiry against the respondent SDO. Hence, not friendly as per
Hon’ble Supreme Court Order.
F. Moreover, Licensees are liable to refund the LPS charged @ 18% from Apr, 2015 on words
with Applicable interest/ Compensation/ Penalty as applicable if charged from consumer.
There is no Limitation Period as per the said Hon’ble Supreme Court order No 1672 of
2020. Moreover, there is no limitation period in general in the Act, 2003 is there and
mistake regarding for the first time realized in October, 2022 as mentioned.

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Suggestion: The LPS in 2024-2025 should be applied on the same principal/ Pattern of
Categories as defined NOTIFICATION Gazette of India Extraordinary, New Delhi, the 31 st
December, 2020: G.S.R. 818(E).----: (11). Consumer as prosumer:-
Most Important: Clause No 6.10.2 of Regulation 29/2014 (Electricity Supply Code) of 8 th
Jan, 2014 with its Amendments (In case of Disputed Bills) “On Review of the Complaint, if
the licensee has paid any excess amount, such excess amount along with interest at saving
bank rate of State Bank of India Current as on 1st of Apr, of the financial year shall be
adjusted in subsequent Bills”.
*The interest at saving bank rate should be replaced with Base Rate of State Bank of India
Current as on 1st of Apr, of the financial year shall be adjusted in subsequent Bills.
G. That it is important to note No. 23/22/2019-R&R Part-4 GOI Ministry of Power in the
name of Sh. Sandeep Naik Director to all the State Governments Power Related
Authorities. However, the copy of same shall be attached. However, the contents of the
letter from subject & Para’s 1 & 2 of the First page is provided below.
That Copy of Draft Sh. Ghanshyam Prasad shall be attached. Emphasize: Licensees were
not only issuing wrong bills but illegal Charges in respect of LPS.
F.C. “Fixed Charges: That as per Hon’ble Supreme Court of India Civil Appellate
Jurisdiction CIVIL APPEAL NO. 1672 OF 2020 (Arising out of SLP (Civil) No. 5190 of 2019)
following important inferences are important.
1. The high-rise buildings BSDS Residential Societies were made on the Basis of Singapore &
under USA “United States of America” under Apartments Owners Act of 1983 with Rules
of 1987 and subsequently Amended/ Substituted by Haryana Registration & Regulation
of Societies Act, 2012 & Rules, 2012.
2. That High rise buildings are made with the concept of less covered area inter-alia not
affecting the greenery area.
3. That Licensee’s DHBVNL & UHBVNL had supplied the ARR but without proposals inter-
alia loop holes.
4. That in the newspaper Hon’ble C.M. of Haryana has stated old tariff shall continue with
the old tariff with additional charge of FSA @ Rs. 0.47 per unit. Meaning by HERC is being
pressurized to accept the Licensee’s ARR without Proposal in the undersigned opinion. As
a matter of fact as per HERC order dated 22th Dec, 2022 in the Case No. HERC Petition no

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56 of 2023 and Petition No 62 of 2023: In The Matter of: Petition for relaxation in levying
of FPPAS (Fuel and Power Purchase Cost Surcharge Adjustment) during the FY 2023-24
under regulation 66, 78 & 79 HERC (Terms and condition for determination of Tariff for
Generation, Transmission, wheeling and Distribution & Retail Supply under Multi Year
Framework) the LPS @ Rs. 0.47 per unit are approved for five quarters inter-alia
absolutely wrong concept. Stake Holder is of confirmed opinion the LPS should be part of
Tariff and not separate as this is to be continued for more than one Financial Year.
Everyone shall appreciate that none shall like the FSA @ Rs. 1.55 per unit as can be seen
in the FY 2016-2017.
It is matter of concern that DHBVNL even admitting the F.C. (Fixed Charges) are being
issued wrongly every month. However, DHBVNL is least bothered to follow Law or
settled law by Hon’ble Supreme Court Reportable Order. Hence, HERC is humbly
requested for stern Direction to Licensee. Stake Holder issues in HERC Petition HERC/
PRO-23 of 2023 next “That DHBVNL as Respondent in Petitioner B.K. Aggarwal in HERC
Petition No 23/2023 had submitted on the Order of E.O. Panchkula Haryana in hand
written Note of by XEN DHBVNL Sh. S.K. Singh Ji RAPDRP Hisar & others inter-alia
DHBVNL & UHBVNL had made their own law i.e. Superseding the Statutory Authority
“E.O. Ombudsman Panchkula Haryana” order in the case of NFL under section 42 (6) of
electricity Act 2003. It is further intimated as per Para 7.1 of Hon’ble Supreme Court
Judgment in Case No 1672 of 2020 important finding, The Standing Committee of Energy
in its Report dated 19.12.2002 submitted to the 13th Lok Sabha, opined that Section 56
of the 2003 Act is based on Section 24 of the1910 Act.
The Standing Committee further opined that a restriction has been added for
recovery of arrears pertaining to the period prior to two years from consumers, unless
the arrears have been continuously shown in the bills. Justifying the addition of this
restriction, the Ministry of Power submitted that: –“It has been considered necessary to
provide for such a restriction to protect the consumers from arbitrary billings.”
In view of every DHBVNL Bill being wrong Distribution Discoms/ Licensees
working is against the Section 56 of Electricity Act 2003.
“Emphasize: Hon’ble Commission with due respect & apology shall ensure Discoms
prepare Consumer’s Bills correctly”.

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5. That Tariff of Consumers of Single Point Supply BSDS at 11 KV and Domestic consumers
has to be compatible for the following reasons particularly on F.C. Fixed Charges.
6. That maintenance of Electricity Switchgear from its gate to the Flat/dwelling units is
maintained by RWA/PVCCA in our case.
7. Transformation loss as per undersigned experience of 1 MVA oil immersed transformer
at no load was 96 units of 24 hours inter-alia 4 units per hour or 4*100/(1000*.9) =.44%
losses per MVA inter-alia for 5 MVA Transformers “Three No’s totaling 5 MVA” it is
equivalent to 2.22%.
8. In the case of Domestic consumers due to unbalance of loads in three phases has/is to be
more as compared to Consumers of Industries inter-alia minimum by 2%. Moreover, if
compared to Domestic Consumers having Licensee meters the deposit is to be made
directly to consumers.
9. In the case of Consumer’s like ours we have to first categories of consumer’s than we
have to prepare the bill as per the Domestic Consumers and Rate of Energy Charges &
FSA is same. However, in the case of domestic there is Rs. Zero per unit.
10. One can say the MMC is being realized by RWA/PVCCA. However, the regular
maintenance of infrastructure involved burden is absorbed by Consumer at 11 KV and
same than MMC in rupees received.
11. Due to additional burden of Fixed Charges i.e. to the tune of Rs. 0.21 per unit at F.C.
Charges @ Rs. 80 per KW of Recorded MDI. Soft Copy of same shall be attached.
12. In view of above facts, the F.C. Charges should be zero. However, at first go the Fixed
Charges Rs. 40/KW of Recorded KW MDI be made without fail. The total Charges of
Different Financial Years excel data is with HERC as well as with DHBVNL. In case of any
Proactive objection or Contradiction is most welcome.
Conclusion: The Fixed Charges should be reduced from Rs. 80/KW of Recorded Demand
to be reduced to Rs. 40/KW of Recorded Demand.
13. TDS: Deduction of TDS from Consumers like ours i.e. Single Point Supply BSDS at 11 KV
of Consumer PVPL (PARK VIEW PVT L) bearing latest DHBVNL A/c No 6307821000
consisting of 608 Flats/Dwelling Units. Meaning by threshold limit for deduction of TDS
should be on Security Interest if More than Rs. 608*5000 = 3040000/-. Moreover, few
related points are provided below. However, even accepting without agreeing Income

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Tax Act, PVCCA as any person still DHBVNL was supposed to handover the related
document so that same may be realized from relevant agencies inter-alia hefty Penalty.
a) There had not been any PAN/ TAN no’s in any of the DHVN prior to Sep. 2022 Bill of
Aug-2022 consumption. However, as per Ld. Counsel UHBVNL Circular That in E.O.
Appeal No 1/2023 DHBVNL counsel Vide Email dated 23.03.2023 had provided one
UHBVNL Memo No 390/AOR/8/21-22 that too cited the case of industry of UHBVNL.
The Copy of DHBVNL Counsel is attached by DHBVNL Counsel.
b) That even after DHBVNL bills issued subsequently PAN No on Bill is ****760Q instead
of our PAN No AABAP7960Q. However, DHBVNL in the HERC hearing on 13.12.2023
in Petition No HERC/PRO-23 of 2023 had shown as ****7960Q. Undersigned shall
provide the affidavit. However, in case Licensee if not agreeing let it be on affidavit to
the Stake holder.
c) That as per UHBVNL said Circular of UHBVNL there has to be penalty on the Operation
Officers for not adhering the Condition of 194A Income Tax of 1961 there is penalty
as mentioned in the UHBVNL Circular i.e. Memo No 390/AOR/8/21-22 Dated:
18.10.21.
d) That DHBVNL Ld. Counsel had Consumers like ours covered under City-Co-operative
Society. However, Petitioner had provided as this information as supportive
document in addition to the Circular of UHBVNL TDS shall be deducted from any
person from Domestic as well as Consumers of PVCCA/RWA with 608 flats/dwelling
units. Moreover, PVCCA refunds/adjust of flat owners bill.
e) That DHBVNL had never provided any documents for depositing TDS certificate to
RWA/PVCCA as a matter of none to Domestic or Condominium like ours. In fact SDO
(OP) Mr. Liyakat Ali in 2017-18 had adjusted Rs. 308506/- @ 10% instead of 20%.
Moreover, for delayed period related with ACD has to adjust as per applicable RBI
Bank Rate or more as per Commission Regulation’s.
f) Adjustment of Security Interest @ RBI Bank Rate as on 1st of April of the year for the
period 1st Apr to 31st Mar of the financial year and to be adjusted in first billing cycle
of the ensuing financial year inter-alia in the DHBVNL Bill of ensuing April. DHBVNL
through its Ld. Counsel had made a mockery of its interpretation. This is important

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the anomaly was removed in HERC 1st Amendment of Regulation 29/2014 dated 17th
Nov, 2014 by amending/substituting clause no 4.15.5.
g) Not timely adjusting the excess security Quarterly i.e. on or before 30th June, of
Ensuing Financial Year. That rate of interest has to be as per clause 20 of Schedule 2
r/w Compensation / Penalty at Sr. No 17 of additional 18% after notice of 30 days vis-
à-vis after 2 subsequent Bills i.e. interest for the period Apr to Mar of the Financial
year in the first billing cycle of ensuing financial year i.e. Apr of Ensuing Financial Year.
Moreover, in the HERC/Petition No 32/2023 on dated 10.01.2023 had imposed
Penalty/Compensation as per HERC Regulation 50/2020 regarding Standards and
Compensation/ Penalty.
h) Three DHBVNL Bills in the back date as sample only i.e. of Jul21-Jun21, Aug21-Jul21 &
DEC, 2017 are attached and wrongs mentioned below.
Bill of Jul, 2021 issued in Aug, 21:
a) Security Interest issued in Aug-21 instead of Apr-21.
b) PAN No has been mentioned as ****7960Q as against Nil?
c) Security before DHBVNL Bill of Jul, 21 for consumption Jun, 21 as per wrong Rs.
654206/- as excess security adjusted out of Rs. 5510000/- inter-alia Rs. 4855794/-?
The Security in DHBVNL Aug-21 has been shown as Rs. (4855794-618348) = 4237446/-
? Audit Department May under half margin may raise demand even after years.
d) F.C. “Fixed Charges” again wrong as not being monthly? DHBVNL/’L had made their
own law i.e. against the Approved Commission Regulations as well as against the
tariff.
e) Wrong LPS Charges and fictitious Arrears.
f) TDS @ 20% shown deducted in the Bill without supply of documents that too if
applicable.
Bill of Jun, 21 consumption issued in Jul, 2021:
a) Wrong Slab Charges i.e. Rs. 6.2 per unit instead of Rs. 5.2 per unit i.e. on Billed units
after 4% rebate on metered Consumption units. The DU is equivalent to
(485601.6/608) =798.69.
b) The Security Deposit has been shown as Rs.4237446/- as against Rs. 4855794/- that
too as per DHBVNL version “Wrong”.

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c) LPS charges are wrong as rate of LPS from 2015 till date has to be zero/Nil.
d) F.C. Fixed Charges is again not monthly. Inter-alia Wrong Municipal Tax also as it is
equivalent to Rs. (Energy Charges + FSA + Fixed Charges)*2%.
e) PAN NO in Back Date has been made as ****7960Q instead of Nil/ Blank.
Prayer:-
• That first of all every bill is wrong hence selling price per unit is not reliable. Meaning
Stern Action against erring officers.
• Wrong LPS charges from Retailers being nil from 1.04.2015 or after 8th Jan, 2014 being
Nil. Hence figure of Rs. 28950.24 lakhs as income is wrong.
• The Security Interest figure for FY 2024-25 as Average Security Deposit of Rs. 2944.80 vis-
à-vis Interest on Consumer Security Deposit of Rs. 198.77 is wrong for the reason
Adjustment of Excess/Deficient of Consumers Security Yearly is not been adhered by
Distribution Discoms.
• The Deduction of TDS from Domestic Consumers as well as from Single Point Supply BSDS
at 11 KV is a big question mark in view of No PAN No’s of Consumers, hence how
deduction of TDS that too without giving the information to consumers implies that
Discoms have deducted TDS @ 20% but not depositing in the appropriate authorities.
• There is no where mentioned about the consumption of Domestic vis-à-vis Single Point
Supply BSDS Condominiums at 11 KV connections.
• The Fixed Charges (FC) of Domestic and Single Point Supply BSDS Condominiums at 11 KV
connections should be same. As intimated at first go the Fixed Charges of BSDS
Condominiums should be reduced from Rs. 80/KW of recorded MDI in KW to Rs. 40/KW
of recorded demand “MDI” KW.
• That Revenue Gap (Negative) being very high figure, Rs. 0.47 per unit should be part of
tariff and not FSA @ 0.47 per unit.
• LPS Rate of Retailers under Chapter 9 of Tariff be clearly new rate i.e. SBI Base Rate as on
1st April of Financial Year and simultaneously clause No 6.10.2 of HERC Regulation
29/2014 with its amendments be made same as LPS rate.
• Inadvertent omissions/shortcomings, addition / change / modification / alteration in the
present submissions may be allowed before 4.01.2024.

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B.K Aggarwal also filed a replication vide email dated 06.02.2024 to the reply filed by
DHBVNL to his observations dated 29.12.2023. He reiterated the dispensations in the
Commission’s approved tariff of FY 2022-23 including the observations on revenue gap
as well as CoS.
DHBVNL Reply
Re: levy of FSA @0.47 paisa per unit
1. Objector has stated that FSA @ Rs. 0.47 per unit had to be part by increasing the tariff
and not be kept separately.
2. In this regard, DHBVNL submits that FSA charges are being levied to the non-AP
consumers as per Regulation 66 of HERC MYT Regulation, 2019 for Timely recovery of
power purchase costs over and above the approved power purchase cost. Further,
DHBVNL humbly submits that any order(s) may be passed by the Hon'ble Commission
regarding levy of FSA to non-AP consumers in the interest of justice, as deemed fit.
Re: ARR Gap
3. Objector has stated that, there should not be any carryover of dues in subsequent
months such as subsidy of AP tube wells. FSA increase or decrease on the increase
cost of fuel as per Licensee submissions for retailers in on Page No 267 of total 307
pages of HERC Tariff on the one side deficit of More than Rs. 1094.54 crores as deficit
Licensees were not able, how this deficit amount shall be met and directed to provide
Proposal along with ARR The DISCOMS same tariff but no reply how the gap could be
managed.
4. In this regard, DHBVNL submits that revenue gap for ARR FY is proposed to be met
from efficiency improvement in subsequent year. Further, DHBVNL humbly submits
that any order(s) may be passed by the Hon'ble Commission in the interest of justice,
as deemed fit.
Re: HERC Petition No HERC/PRO-23 of 2023
5. Objector has stated that, DHBVNL had admitted the Fixed Charges knowing well are
being issued wrongly and SDO (OP) one excel sheet of 42 months i.e. due to one
excuse or other. It also submitted that DHBVNL as Respondent in Petitioner B.K.
Aggarwal in HERC Petition No 23/2023 had submitted on the Order of E.O. Panchkula
Haryana in hand written Note of by XEN DHBVNL Sh. S.K. Singh Ji RAPDRP Hisar and

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others in Annexure R-4 Page No. 20 of Respondent DHBVNL in the reply with Affidavit
dated 29.09.2023 action that too through regular Licensee Ld. Counsel
DHBVNL/UHBVNL had superseded the Statutory Award by E.O. Panchkula speaks
volumes regarding extortion of money from consumers. Further, objector has
submitted that there being no mention of PAN/TAN no’s of Consumers Bills before
DHBVNL Bills issued in Sep, 2022. In absence of PAN No’s of Consumer’s there cannot
be deduction less than 20% before 2018. As a matter of fact DHBVNL had adjusted
Deduction of TDS 10% in the period Apr, 2016 to Mar, 2018. Accordingly, objector has
requested to the Commission for Direction as deems fit so that Licensee shall not
extortion of Consumers Money. Wrong Justification of Deduction of TDS by Licensee’s
through regular Ld. Counsel on 13/12/2022 hearing in HERC Petition No HERC/PRO-
23 of 2023
6. DHBVNL humbly submits that, Tariff to consumers are being charged as per Hon’ble
HERC Tariff Order for the relevant year. Further, it is submitted that above matter is
sub judice in HERC 23 of 2023 and is under process of hearing. Accordingly, any
order(s) may be passed by the Hon'ble Commission in the interest of justice, as
deemed fit.
Commission’s Observation
The Commission has taken note of the objections/comments filed by Sh. B.K. Aggarwal. The
issue of rate of delayed payment surcharge has already been dealt earlier in this order. The
Commission is seized with the issue of billing given the large number of dead/defective/slow
meters and the large number of bills issued on a provisional basis as well as lack of a separate
accounting head for collection of arrears. Further, the issue of TDS has to be necessarily in line
with the governing law/rules issued by the Central Government. Additionally, FSA is being
levied as per the provisions of the HERC MYT Regulations in vogue.

2.3.6 Anagha Pujari

Comments and objection vide email dated 04.01.2024 received from Ms. Anagha Pujari is as
under: -
“That comments being writing to you with a keen interest in understanding how UHBVNL and
DHBVNL have been using advanced Analytics in the control period for addressing various

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challenges faced by them and how they plan to use such technologies going forward. I am
particularly interested in understanding the extent to which AI/ML powered Analytics
Technologies are being employed to tackle critical issues such as Deviation Pool Optimization
through Demand and Generation Forecasting, Load Balancing, Theft Detection, Fraud detection
in Procurement, Predictive Asset Analytics, Data Integration across various platforms, Network
Data Analytics, KPI monitoring, etc. In light of the increasing complexities in the power sector,
leveraging advanced analytics seems imperative for UHBVNL and DHBVNL to enhance
operational efficiency and improve overall performance.
Specifically, I would appreciate information on the following points for FY 23 through FY 25
(Control Period):
1. Current Initiatives: What AI/ML analytics technologies are currently in use across various
departments? Examples include Deviation Pool Optimization, Data Integration at SLDC,
Asset Predictive Analytics, etc. Whether these costs are being considered in Opex or any
specific Capex project has been approved.
2. Future Plans and Roadmap: Whether any Capex projects have been approved/proposed
in this regard for the years in contention? What is UHBVNL and DHBVNL's vision for
incorporating advanced analytics in the future? Does it have any road map in this regard?
Please provide insights into the planned initiatives, technologies, and a roadmap for their
implementation.
3. Cross-Departmental Implementation: It would be valuable to know whether analytics
technologies are being utilized uniformly across different departments within UHBVNL
and DHBVNL or if there are plans to expand their usage.
4. Setting up a Center of Excellence (CoE): Considering the breadth and depth of analytics
applications, Are UHBVNL and DHBVNL contemplating establishing a Center of Excellence
dedicated to analytics? Have UHBVNL and DHBVNL carried out any feasibility study for
setting up such a center for comprehensive Data driven Decision-Making?
I believe that insights into UHBVNL and DHBVNL's strategies and plans would be beneficial for all
stakeholders including customers.
I appreciate your attention to this matter and look forward to receiving comprehensive
information. If needed, I can arrange to meet the concerned people at HERC to further clarify my
queries. However, I do not intend to put across Suggestions and Objections in Person.”

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UHBVNL Reply
It has been submitted by the Nigam, by way of the present reply, that the objections / comments
filed by the intervener herein is not in accordance with the modalities specified in the public
notice issued for inviting objections / suggestions / comments from the general public /
stakeholders, hence, the comments filed by the instant intervener ought not to be considered.
Commission’s Observation
The Commission has perused the above comments / information sought. Despite the fact that
in the present context the answers sought are not directly relevant, the intervener may note
that the distribution system in the backbone of the power system, hence, efforts are made to
absorb new and emerging technologies including AI.
2.3.7 Varun Sharma, Advocate representing BPCL, IOCL & HPCL
Comments vide filing dated 12.01.2024 received from Sh. Varun Sharma on behalf of -
• Bharat Petroleum Corporation Ltd. a Company incorporated under the Companies Act, 1956
having registered office at Bharat Bhawan, 4 & 6 - Currimbhoy Road, Ballard Estate, Mumbai
through its Territory Manager (Retail) and constituted attorney, Bharat Petroleum
Corporation Ltd., at Lalru, Teh. Dera Bassi, Distt. SAS Nagar (Punjab).
• Indian Oil Corporation Limited, a Company incorporated under the Companies Act, 1956
having registered office at Indian Oil Bhawan, G-9, Ali Yavar Jung Marg, Bandra (E), Mumbai
– 400 005 through its Divisional Retail Head, IOCL Panipat Divisional Office, Panipat Refinery,
Panipat 132140
• Hindustan Petroleum Corporation Limited, Petroleum House 17, Jamshedji Tata Road,
Mumbai, Mumbai, Maharashtra, Mumbai, 400020 having its Retail Regional Office at E-22,
Industrial Area, Court Road, Panipat, through its Sr. Regional Manager and Constituted
Attorney
are as under:
i. Statement of the relief sought from the Commission: In view of facts detailed in this
Objection Petition, the Oil Marketing Corporations (OMCs) seek For Providing LT connections
to Electric Vehicle Charging Stations to be set up at retail petroleum outlets of the OMCs in
pursuance to policy of the Government of India on global EV30@30 campaign, which targets
to have at least 30% new vehicle sales be electric by 2030:
ii. The relevant facts and reasons why the Commission should grant the requested relief:

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1. Government of India has supported the global EV30@30 campaign, which targets to have
at least 30% new vehicle sales be electric by 2030. In line with the said policy of the
Government of India to achieve transition to electric mobility for decarbonizing the
transport sector, the NITI Aayog has issued a handbook on Electric Vehicle Charging
Infrastructure. The mandate is to provide an accessible and robust network of electric
vehicle charging infrastructure being essential pre-requisite to achieving this ambitious
transition. The Government of India has instituted various enabling policies to promote
the development of the charging infrastructure network. However, given the novel
characteristics of this new infrastructure type, there is a need to customize it to the unique
Indian transport ecosystem and build capacity among stakeholders to support its on-
ground expansion. It is thus necessary to ensure the efficient and timely implementation
of EV charging infrastructure, such that it meets local requirements and is optimally
integrated within the electricity supply and transportation networks. Chapter 2.2.2 of the
handbook relating to executive or implementing authorities provides as under:-
“Under the MoP’s direction, states have nominated state nodal agencies (SNAs) to govern
the implementation of public charging. SNAs are mandated to select implementing
agencies to install, operate and maintain public charging stations and battery swapping/
charging facilities in the state. Unless otherwise specified by the state, state electricity
distribution companies (DISCOMs) are the SNAs by default. A complete list of SNAs is
provided in Annexure B.”
Sr.No.19 of Annexure B mentions Uttar Haryana Bijli Vitran Nigam is named as State Nodal
Agency for the State of Haryana.
Under chapter 5 of the Handbook, it is obligation of the DISCOMs to provide electricity
connections for EV charging infrastructure since DISCOMs enforce and execute the
electricity supply rules and regulations on-ground and interact with different classes of
electricity consumers. Chapter 5.1 has noted that the type of connection – i.e., single-
phase LT, three phase LT, or high-tension (HT) – is decided based on the required
sanctioned load which directly impacts the cost and time for getting a connection, the
tariffs, and the need for ancillary upstream infrastructure like Distribution Transformers
(DTs). An HT connection attracts higher installation and monthly demand charges,
involves more time for energization, and requires the set-up of ancillary electrical

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infrastructure by the applicant. The sanctioned load ceilings for LT and HT connections
vary significantly between states.
While emphasizing the need to cater power supply to this new segment of consumers, it
has been noted as under:-
“A system upgrade is advised when the capacity utilization of the nearest feeder is
expected to exceed the permitted threshold (commonly 70%) upon award of a new
connection such as a charging infrastructure connection. Augmentation of the
distribution network can be an expensive and time-consuming affair. A distributed public
charging network can optimize the time and costs associated with getting power
connections for EV charging, with lower sanctioned loads and fewer charging points at
each site. In cases where a greater number of charging points is required or mandated
through building byelaws and other government orders, these provisions can also lead to
higher capital and operational costs, and can disincentivize EV charging installations.
SERCs and DISCOMs need to recognize EV charging as a new type of consumer
requirement, distinct from existing consumer categories, and adapt the supply code to
enable affordable and reliable electricity supply for charging infrastructure.”
Relevant part of the handbook issued by NITI Aayog is annexed herewith as Annexure A.
2. That attention of this Hon’ble Commission in this regard is invited to one of the follow up
meetings under the Chairmanship of Member Secretary, NCR Planning Board regarding
decision taken in the meeting of Committee of Transport Secretaries/Commissioners
(CoTS) held on 09.11.2023 on the matter of Electric Vehicle Charging Station infrastructure
in NCR, which was attended by various representatives of Haryana Power
Utilities/DISCOMs. It was decided in the said meeting that –
“2(iii) Further, on the request of representatives of Rajasthan and Haryana, it was agreed
that all OMCs will send proposals to the RERC and HERC (Haryana Electricity Regulatory
Commission) for required LT connections. In this regard, a draft can be shared by
representatives of UHBVNL.”
Relevant part of minutes of meeting dated 09.11.2023 is enclosed as Annexure B.
3. That the OMCs have decided to set up Electric Vehicle Charging Stations in large number
of retail petroleum outlets, it is not possible to have HT connection keeping in view the
norms laid down by the Petroleum and Explosives Safety Organization considering the

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nature of products dispensed at the retail outlets. There would be requirement of Three
Phase LT connections upto 200 KW. A copy of relevant part of Petroleum and Natural Gas
Regulatory Board (Technical Standards and Specifications including Safety Standards for
dispensing of Automotive Fuels) Amendment Regulations, 2022, are attached herewith as
Annexure C.
4. That there is no tariff category of Electric Vehicle Charging Stations existing in the
regulations of Haryana power utilities/DISCOMs. Under existing regulations maximum LT
load can be given upto 50 KW which would be highly inadequate for prompt charging of
vehicles at the retail outlets. A copy of the Tariff Categories of Haryana DISCOMs is
enclosed as Annexure D.
5. That there was no provision in the rules/regulations laid down by DISCOMs of other States.
Going by the aforesaid policy of Government of India, the State of Uttar Pradesh has made
necessary changes in its norms/rules/regulations to provide for LT connection for Electric
Vehicle Charging Stations. State of Delhi has already made provisions in the year 2017
whereby LT connection upto 200 KW can be issued. Copies of relevant documents issued
by both the States are enclosed as Annexure E & F, respectively.
That in the peculiar circumstances, your kind indulgence is warranted so that the required
rules/regulations/bye-laws related provisions are put in place by Haryana Power
Utilities/DISCOMs to enable OMCs to set up and make Electric Vehicle Charging Stations
operational at their existing retail petroleum outlets.
6. That the counsel for the OMCs had visited the office of HERC for filing a petition on the
instant issue and had met Director/Tariff, HERC, Panchkula from where it was learnt and
as suggested, the instant objections are being filed. It may be stated though the last date
for submission of objections in the public notice was 29.12.2023, the same may be
condoned and the instant objections may be entertained and placed before the
Commission for public hearing on 24.01.2024 so that the issue raised by the OMCs in the
instant objection petition also gets resolved.
It is, therefore, prayed that the Haryana Power Utilities/DISCOMs may be directed to put
in place the requisite framework to enable the OMCs to set up and make Electric Vehicle
Charging Stations operational at their existing retail petroleum outlets promptly by

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providing them LT connections upto 200 KW in line with the policy of the government of
India, in view of detailed submissions made above.
UHBVNL Reply
Vide Memo no. Ch-102/RA/F-25/Vol-84 dated 13.02.2024, the reply of UHBVNL is as under:
1. The present Petition has been filed by Haryana Discoms for determination of ARR and
Tariff for FY 2024-25, Annual Performance Review for FY 2023-24 and True up for FY 2022-
23 under HERC Terms and Conditions for Determination of Tariff for Generation
Transmission Wheeling and Distribution and Retail Supply under Multi Year Tariff
Framework Regulations 2019 and Section 45 46 47 61 62 64 and 86 of the Electricity Act
2003 read with the relevant guidelines.
2. The instant reply is filed by UHBVNL to the objections raised by BPCL, IOCL, and HPCL
(“Objectors”) to the Petition as under:
i. Objectors has stated that they seek LT connections to Electric Vehicle Charging
Stations to be setup at their large retail petrol pump outlets in pursuance to policy
of the Government of India on global EV30@30 campaign. It has also submitted that
Government of India on global EV30@30 campaign is targeting to have at least 30%
new vehicle sales be electric by 2030 and mandate to provide an accessible and
robust network of electric vehicle charging. Thus, the OMCs have decided to setup
Electric Vehicle Charging station in large retail petroleum outlet, and there would
be requirement of three phase LT connection up to 200kW. However, it is not
possible to have HT connection keeping in view the norms laid down by the
petroleum and Explosive Safety Organization considering the nature of product
dispensed at the retail petroleum outlet. Objector has further stated that, as per
existing regulations maximum LT load up to 50kW can be given, which would be
inadequate for prompt charging of vehicle at retail outlets. Therefore, objector has
requested Hon’ble Commission to place the requisite framework to provide LT
connection up to 200 KW.
ii. In this regards UHBVNL submits that, electricity connections to Electric Vehicle
Charging Stations are released by UHBVNL as per HERC (Terms and conditions for
release for setting up charging infrastructure, tariff and other Regulatory issues for
Electric Vehicles), Regulations 2021 (circulated by UHBVNL vide Sales Circular-

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04/2022 on 21.03.2022). It is further submitted that Classification of Supply voltage

for releasing the connection is done as per the HERC Electricity Supply Code
Regulations (UHBVNL Sales Circular No. U-02/2020), under which LT connection can
be released only up to 50 KW load and above 50 KW load, connection is to be
released on HT supply only. The relevant clause is reproduced as under: -
“3.2 Classification of Supply
(a) Supply shall generally be given at the following voltages on the basis of
contracted load:
Category System of Supply
Low Tension
Contracted load upto 5 kW Single phase at 230 V
Contracted load above 5 kW and up to 50 kW 3 Phase 4 wire at 400 V
High Tension
Contracted load exceeding 50 KW and up to 5000 kVA 3 Phase at 11 kV
Contracted load exceeding 2000 kVA and up to 25000 kVA 3 Phase at 33 kV
Contracted load exceeding 5000 kVA and up to 75000 kVA 3 Phase at 66 kV
Contracted load exceeding 25000 kVA and upto 100000 kVA 3 Phase at 132 kV
Contracted load exceeding 75000 kVA and upto 320000 kVA 3 Phase at 220 kV
Contracted load exceeding 320000 kVA 3 Phase at 400 kV

iii. It is worthwhile to submit that in order to provide better and quality power supply
to the consumers, the intent of DISCOMs as well as of the Hon’ble Commission
has always been to provide more and more consumers, connections at HT
pressure. This can also be seen from the Classification of Supply which has been
amended time to time as follows: -
Year Category System of Supply
1980 Contracted load upto 100 kW Low Tension
Contracted load exceeding 100 kW High Tension
w.e.f 1987 Contracted load upto 70 kW Low Tension
Contracted load exceeding 70kW High Tension
w.e.f 2010 Contracted load upto 50 kW Low Tension
Contracted load exceeding 50 kW High Tension

iv. HT:LT Ratio: Better voltage supply and reduced distribution losses are the factors
that drive DISCOMs to maintain high HT:LT ratio. UHBVNL’s performance in this
regard is as follows: -

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FY HT Lines LT Lines Ratio

2013-14 53118 52312 1.02
2014-15 55056 52753 1.04
2015-16 55990 52998 1.06
2016-17 56745 53622 1.06
2017-18 57691 54174 1.06
2018-19 58858 55448 1.06
2019-20 59662 55842 1.07
2020-21 61550 56328 1.09
2021-22 63911 57438 1.11
2022-23 65344 58887 1.11
v. It is submitted that the Objectors are seeking such a relaxation on the ground of 2
reasons which are (1) Safety and (2) HT connections costs more. These are replied
as under:
vi. So far safety issue is concerned, the relevant portion of Petroleum and Natural Gas
Regulatory Board (Technical Standards and Specifications including Safety
Standards for dispensing of Automotive Fuels) Amendment regulations, 2022
which is attached as Annexure-C of the Objections provides for the filling facility to
be free from overhead electric cable or HT line as under: -
(iv) There shall be no overhead electric cable or HT line above the filling “facility.”
a. It is submitted that with HT connections, this provision can easily be
taken care of by placing the Distribution Transformer and HT meters at
appropriate place such that no overhead electric cable or HT line should
pass over the filling “facility. The Electricity Supply Code Regulation,
2014 (with up-to-date amendment) also provides provision for fixing the
place of DT and Meter in consultation with the consumer as under: -
(6) During the inspection of the premises, the licensee shall:
(a) Fix the point of supply and the place where the meter and other
equipment shall be installed, in consultation with the consumer.
b. Furthermore, if there are safety issue with HT connections which are to
be released to filling stations then it will be there irrespective of
connected load whether it is 200KW/KVA or beyond. So, OMCs should
seek relaxation for LT connection irrespective of applied load. Their
objection for only applied load upto 200kW/kVA clearly shows that they
are not approaching the Hon’ble Commission with clear hands.

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7. The second aspect is costing. Objectors have stated that HT connections would cost
much costlier to them in terms of higher tariff, additional demand charges and higher
installation charges, more time of energization.
a. In this context, it is submitted that for promoting and facilitation the Electric Vehicle
Charging Stations in Haryana following provisions are already in place which have not
been considered by the Objectors:
(a) Separate Tariff Category
Electric Vehicle Charging Stations are separately categorized by the Hon’ble
Commission in ARR/Tariff Order since FY 2021- 22.
(b) Relaxed Tariff (with No Fixed Charges):
The applicable tariff for LT & HT connections for Electric Vehicle Charging Stations
as determined by the Hon’ble Commission for FY 2023-24 is a single part tariff
equivalent to Cost of Supply for LT/HT as under:
“The tariff for electricity supply to 'the EV Charging station in Haryana shall be a
single part tariff equivalent to the CoS of HT Supply (i.e. Rs.6.22) and LT Supply
(i.e. Rs.6.62), as determined in the present order. The off peak / night time
concession benefits shall also be applicable. There shall be no fixed / demand
charges.”
(c) Relaxed Installation Charges:
To rein in cost of installation, HERC (Terms and Conditions for setting up Charging
Infrastructure, Tariff and other Regulatory issues for Electric Vehicles),
Regulations, 2021 has provisioned that for E-Vehicle Charging Station(s) the cost
of separate / dedicated transformer along with allied equipment shall be born by
the DISCOMs out of their CSR fund. The relevant clause 17(f) is reproduced as
under for kind reference: -
“In case of HT connection for E-Vehicle Charging Station(s) for load more than 50
kW, the cost of separate / dedicated transformer along with allied equipment
shall be borne out of CSR fund of Discoms to rein in cost of installation(s).”
(d) Release of Connection on Priority
To ensure expeditious release of electrical connections to EV Charging Stations in
Haryana, the Hon’ble Commission has already made a provision in HERC (Terms

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and Conditions for setting up Charging Infrastructure, Tariff and other Regulatory
issues for Electric Vehicles), Regulations, 2021 for releasing connections on
priority as under: -
Any person seeking to set up a Public Charging Station may apply for connectivity
and he shall be provided connectivity on priority by the Distribution Company
licensee to supply power in the area. Discoms shall release such connections on
priority subject to the developers making all the related payments upfront as per
relevant HERC Regulations.
b. These submissions clearly state that provisions for addressing the concerns of
objectors (for such a seeking relaxation) are already in place and hence the Objectors
need to review their objections while keeping in view the above.
8. Relaxation given by Uttar Pradesh and Delhi
a. The Objectors have stated that the State of Uttar Pradesh has made necessary
changes in its norms/rules/regulations to provide for LT connection for Electric
Vehicle Charging Stations and have also enclosed copy of relevant document as
Annexure-E.
b. A bare perusal of the order dated 08.08.2023 issued by Uttar Pradesh Power
Corporation Limited would reveal that though they have permitted release of
electrical connections to EV Charging Stations on LT pressure beyond 50kW,
however, this change will not benefit the OMCs in terms of costing as point 3 of
the order clearly states that the applicant has to bear complete cost if the
proposed connection required augmentation or extension of electrical
infrastructure.
c. Also, the State of Delhi has not provided such a classification of Service exclusive
for EV Charging Stations. Further, the individual states have different consumer
base and demography, as such, policy of one State cannot be entrusted on
other. Haryana is already recognizing Electric Vehicle Charging Stations as
separate category and has taken several initiatives in order to promote and
facilitate their growth in the State as detailed in para 7.

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9. Adjudication by HERC
It is relevant to add here that the Hon’ble Commission vide order dated 20.12.2021 in
case No. HERC/PRO-67 of 2020 in the matter of charging infrastructure, Tariff and other
Regulatory issues for electric vehicles has adjudicated the present issue by recording in
Sr. No.9 of point No.9 as under: -
“However, additional expenses i.e. cost of transformer etc. shall be borne from the CSR
fund of the DISCOMs to keep the cost of infrastructure to be recovered from EVs as low
as possible.”
10. Apart from above, the objections raised by the Objectors are replied as under: -
11. In point No.5, objector has further stated that there is no tariff category of Electric Vehicle
Charging Stations existing in the regulations of Haryana power utilities/DISCOMs. This
statement is not true as the Commission has already defined electric charging station as
a separate tariff category. As described in the notes to the tariff schedule, the tariff for
electricity supply to the EV Charging station in Haryana is a single part tariff equivalent to
the CoS of HT Supply (i.e. Rs.6.22) and LT Supply (i.e. Rs.6.62), as determined in the tariff
order dated 15.02.2023. The off peak / night-time concession benefits are also available
to EV charging stations.
12. Furthermore, the objectors have erroneously understood that there are demand charges
on EV charging stations. As per currently applicable HERC tariff order, there are no
demand/fixed charges on EV charging. Hence, EV Charging stations in Haryana are already
provided benefits of single part tariff equivalent to the HERC approved HT or LT Cost of
Supply.
13. In the objection, the objectors have also mentioned that HT connection will attract higher
installation charges. Discoms would like to submit that most of the petrol pumps are
already near an HT line and thus it is unlikely that any major additional infrastructure/line
would be required to be constructed in majority of the cases. In turn, they will also benefit
from the relatively low tariff of Rs. 6.22/kVAH which is currently Rs. 6.65/kVAH for other
11 kV HT consumers and Rs. 6.65-6.40/kVAh for LT consumers with load greater than 10
kW.
14. The distribution losses of the Discoms are prudently approved by Hon’ble Commission
and those approved losses are loaded on the consumers as per approved power purchase

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cost calculated by considering approved transmission and distribution losses. Hence,

Discoms have a regulatory, legal, and social obligation to reduce the losses as much as
possible. Issuing connections of 200 kW at LT will only increase Discoms’ overall system
losses as LT losses are additionally incurred after HT network. Not only this, Discoms have
always tried to increase the HT:LT ratio as not only it helps in reducing losses, but threat
of theft is also reduced in HT network. This is one of the reasons that Haryana Discoms
are in the top best performing state discoms.
15. It is highly expected that, in the future, the approved losses by HERC will follow a
decreasing trend only. It will be detrimental for Discoms’ financial and operational health
if any leeway is given in current regulations by giving EV connections of >50 kW at LT
because more and more LT connections of >50 kW will only degrade Discoms overall
technical losses.
16. It is to be noted that Discoms are one of the designated customers under BEE PAT scheme
and any distribution loss of Discom is a loss or waste of energy procured. As Coal/Gas
based power plants still contribute around 60%-65% of the energy procured at national
level, issuing LT connections of >50 kW will directly contribute to increase in Discoms
distribution losses and thus possible increased wastage of power purchased from
Coal/Gas power plants. Given the country is following the path of reducing carbon
footprints and Net Zero by 2070, reducing distribution losses now becomes more and
more obligatory to Discoms.
17. As per NITI Aayog report, as soon as the adoption of EV vehicles is increased, availability
as well as demand for high-power chargers (>50 kw per charger) is going to increase in
near future. This is evident from the fact that first generation LCVs have around 21 kWh
of battery capacity and require 72 V whereas the 2nd generation require 350-500 Volts.
In addition, one of the prominent economic standards for EV charging is Combined
Charging System (CCS) that can deliver power up to 350 kW and with wide operating
voltage of 200-1000 V DC. The voltage and current requirement will only increase in the
near future due to improvement in the technology, resulting in increased demand for fast
charging (i.e., high power chargers) from consumers as they will be less inclined to wait
in a que or at EV charging stations installed in a mall or highway for 4-5 hours.

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18. It is also given that the per unit cost of purchased power is only going to increase in near
future. Hence, increased system losses (due to giving more LT connections at higher kW)
will increase cost burden on the Discoms and consumers alike as costlier power will be
lost in the LT systems because of increase in per unit cost of supply.
19. UHBVNL would also like to humbly submit that due to highly regulated business, Discoms
are allowed only prudent costs and a moderate return on equity. On the other side, all
objecting OMCs are Maharatnas (greater than Rs. 5000 Crs of net profit in three
consecutive years and annual average net worth of more than Rs. 15,000 Crs) and highly
profitable. They are financial behemoths, and their financial prowess is evident from the
fact that the combined Profit after Tax (PAT) of BPCL, IOCL, and HPCL was a whopping Rs.
57,000 Crs (that too for only first 6 months ending September 2023) in comparison to ~Rs
111 Crs PAT of UHBVNL for the whole year of FY 2022-23. Giving any financial incentive
on EV tariff or any leeway on connection voltage infrastructure will be completely against
the normal business economics, social welfare, and environmental obligation of the state
as well as Discoms.
20. Discoms are also getting adversely affected due to low power factor at LT end. At HT, as
the billing is in kVAh, consumers themselves ensure a good power factor at their end. The
low LT system power factor increases apparent power in the system, resulting in drawl of
more reactive power in the system and corresponding increased reactive charges on
Discoms from HVPNL.
Conclusion: UHBVNL has submitted to consider the submissions presented in this reply and, in
light of the information provided, may not consider the petition of the objectors and uphold the
provisions of HERC Electricity Supply Regulations (with up-to-date amendment).
DHBVNL Reply
Vide Memo no. Ch. 16 /SE/RA-781 dated 30.01.2024, the reply of DHBVNL is as under:
In this regards DHBVNL submits that, electricity connections to Electric Vehicle Charging Stations
are released by DHBVNL as per Sales Circular No. D- 03/2022, 28.01.2022. Further, it is humble
submission to Hon’ble Commission that as per Duty to Supply Electricity Regulations, DHBVNL is
bonded to release LT connection up to 50KW only and load exceeding 50 kW shall be catered on
11 KV and above.

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Further, DHBVNL humbly submits that any order(s) may be passed by the Hon'ble Commission
regarding EV charging station in the interest of justice, as deemed fit.
Commission’s Observation
The Commission has carefully perused the submissions of the counsel appearing for the oil
marketing companies. It needs to the appreciated that LT:HT ratio has to be moved towards
HT supply so as to ensure that quality in terms of voltage and frequency is taken care of and
technical loss is reined in. Hence, extending LT supply upto 200 KW will set the initiatives taken
by the Commission, regarding this, back in time.
The Commission in consideration of the fact that due to plethora of benefits, EVs and EV
charging stations are to be encouraged. Consequently, the Commission has allowed
concessional tariff with no fixed cost as well as extended ToD Tariff benefits to them.
Moreover, to cushion the cost, the Commission has made provision specifically for the EV
charging stations that the cost of HT transformers and associated equipment shall be borne by
the power utilities up to a load of 200 kW as the request of BEE and HAREDA . Additionally, the
safety aspects can be addressed by installing combined CT / PT unit for metering at H Pole on
one corner of the EV Charging Station along with transformer on H Pole & taking LT supply
inside the charging station as practically this would tantamount to giving supply on LT. No
additional cost is borne by the EV Charging Stations up to a load of 200 kW. Hence, the
Commission has already adequately addressed the concerns of Oil Marketing Companies.
2.4 Public Hearing
In order to provide ample opportunity to the stakeholders to present their views before the
Commission, the public hearing in the petition(s) under consideration was held on 08.02.2024 at
10:00 AM in the Court Room of the Haryana Electricity Regulatory Commission at Panchkula. The
petitioner(s) made a detailed presentation in the hearing and also responded to various
queries/clarifications sought by the Hon’ble Commission. Only one intervenor was present in
person during the hearing namely Mr. Varun Sharma, an advocate representing BPCL, IOCL and
HPCL. The intervenor present in the hearing re-iterated the comments and prayers made by him
in writing.

Further, the submissions made by the Interveners as well as the Commission’s view on the same
have already been reproduced earlier in the present Order. Hence, for the sake of brevity the
same are not being repeated here.
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2.5 Additional Data/ Information filed by the DISCOMS

The Discoms provided the additional information / data sought by the Commission from time to
time. The same i.e. information sought by the Commission and Discoms reply thereto have been
taken on record of the present proceedings. Hence, they are not reproduced here.

2.6 State Advisory Committee (SAC)

In the consultation process for giving a final shape to the order for FY 2022-23 (True-up), APR
(2023-24) and distribution and retail supply ARR / tariff (FY 2024-25). The Commission, to have
the benefit of the views / suggestions of the Members of the SAC, convened a meeting of the
State Advisory Committee, constituted under Section 87 of the Act, on 09.02.2024. The SAC
meeting was convened to discuss the petition filed by the Haryana Power Utilities including that
of UHBVNL and DHBVNL. At the onset, the Hon’ble Chairman underscored the significance of
technical audit of both the power distribution licensees. He also pointed out the need for
adopting good O&M practices including preventive and predictive maintenance of the
distribution system.
Shri V.S. Ailawadi, Member SAC, suggested that the ‘Fixed Cos’t as well as the true-up claims of
all the power utilities need close scrutiny so that quality power is supplied to electricity
consumers at an affordable rate. He raised the issue of ensuring quality of power supply to the
consumers connected at LT Voltage, increasing the percentage of RE in the energy mix of the
State, full and effective utilization of R&M and Capex approved by the HERC, NDS supply side
management and the need for ensuring that the subsidy committed by the State Government is
disbursed fully and in a timely manner.
The operational and financial performance of the two distribution licensees of Haryana viz. Uttar
Haryana Bijli Vitran Nigam (UHBVNL) and Dakshin Haryana Bijli Vitran Nigam (DHBVNL) were
deliberated at length. Shri P.C. Meena, Managing Director of DHBVNL, at the onset, informed
that the Haryana Discoms have achieved A+ ratings on quite a few operational parameters, while
on the consumer related issues the ratings have improved from B to B+. He informed that the
Discoms are making concerted efforts to improve upon the problematic’s areas relating to
metering, billing and collection of bills. He further informed that the Distribution System losses
have been reined in and is well below the regulatory benchmark of 12% and the revenue
collection efficiency, including arrears, exceeds 100%. Additionally, efforts are being made to

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promote pre-paid metering / smart meters despite the fact that the implementing agency i.e.
EESL has almost withdrawn from the project to install 10 lakhs smart meters. He also mentioned
that they have substantially implemented the Hon’ble CMs flagship projects of Mahara Gaon
Jagmag Gaon (MGJG). Resultantly, all the eligible villages are getting almost 24*7 supply of
electricity. The MD Shri Meena briefly mentioned about a few progressive steps such as monthly
billing app and digital transaction touching 69.15%. The Hon’ble Chairman suggested that the
Discoms should promote pre-paid / smart meters, improve upon the O&M practices to ensure
system reliability and minimize billing disputes. Shri Naresh Sardana, Hon’ble Member pointed
out the fact that quite a few RDS Feeder are still reporting more than 50% losses and this would
make the distribution loss figures a misnomer. He also pointed out the issue of non-
implementation of CGRF orders by DHBVNL and issue of provisional bills by the Discoms even
after six months leading to lot of litigations. Additionally, Shri Sardana pointed out the issue of
non-receipt of bills based on net-meters installed for the solar systems installed by the
consumers. The Hon’ble Member Shri Garg suggested that all costs ought to be rigorously
monitored and reined in so that the cost of delivered power can be reduced. He emphasized the
need to install accurate meters, correct reading of the meters and accordingly issuance of correct
bills to the electricity consumers. The MD / DHBVNL informed the SAC Members that there are
certain areas of concern and efforts are being made to address the issue of theft / feeder losses
in such areas reporting high feeder level losses. He further said the issue of bills on the basis of
net metering is being sorted out.
In conclusion, the Hon’ble Chairman Shri Nand Lal Sharma said that the end objective of the
Haryana Power Utilities as well as the Electricity Regulatory Commission is to bring in efficiency
into the entire eco system of power generation to transmission and distribution and retail supply
of electricity. He thanked the SAC Members and the representatives present for their valuable
updates and suggestions. The Commission will keep the views of SAC Members in mind while
issuing the ARR / Tariff orders of distribution licensees.

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CHAPTER 3
ANALYSIS OF ARR FILINGS AND COMMISSION’S ORDER

The Commission, while passing this Order for True-up of the FY 2022-23, Annual (Mid-year)
Performance Review of the FY 2023-24 and determination of ARRs of the UHBVNL and DHBVNL
for the FY 2024-25, has considered the provisions of the Electricity Act, 2003, HERC MYT
Regulations, National Tariff Policy and all the relevant data / information placed on record by the
parties from time to time.

3.1 True-up of the ARR for the FY 2022-23

The Discoms have submitted that true up petition(s) submitted by them are in line with the
Regulation 13 of the MYT Regulations 2019. The truing up of uncontrollable items and
controllable items (subjected to force majeure conditions or variations attributable to
uncontrollable factors) are adjusted appropriately in the ensuing year through tariff resetting.
The Discoms have further submitted that for truing up of the ARR of the FY 2022-23, the actual
expenditures of UHBVNL and DHBVNL have been considered as per the audited annual accounts.
The True-up petitions filed by the Discoms have been examined by the Commission in the light
of the MYT Regulations including its subsequent amendment(s), relevant Orders of the
Commission and the audited accounts for the FY 2022-23 placed on record by the Discoms
keeping in view of details of audited expenses, income and corresponding revenue gap against
the respective approved values.

3.2 Operation & Maintenance Expenses (O&M)

It has been submitted by the distribution licensee(s) that Operation & Maintenance Expenses of
the Distribution licensees include the following-
i. Employee Expenses including retiral benefits.
ii. Repair & Maintenance Costs (R&M) and
iii. Administrative and General Expenses (A&G)
It has been averred that the Employee Expenses consist of salaries, dearness allowance, bonus,
terminal benefits in the form of pension & gratuity, leave encashment and staff welfare
expenses.

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Repair and Maintenance expenses include regular expenditure made for improvement of system
reliability and quality of power supply. These expenses are important for system maintenance
and loss reduction in the distribution network.
Administrative expenses mainly comprise of rents, telephone and other communication
expenses, professional charges, conveyance and travelling allowances etc.
True-up proposed by UHBVNL:
Actual O&M expenses incurred by UHBVNL as against the approved expenditure (after deducting
the amount capitalized), as submitted by the distribution licensee are as follows: -
UHBVNL proposed O&M Expenses for FY 2022-23 (Rs. Crore)
Approved for FY Audited/Actual
2022-23 in T.O. dt. for Difference
Particulars
30.03.2022 FY 2022-23 (C=B-A)
(A) (B)
Employee Expenses 859.40 857.53 -1.87
Administration & General Expenses 112.85 199.15 86.30
Repair & Maintenance Expenses 158.69 93.72 -64.97
Terminal Liabilities 500.00 543.25 43.25
Total 1,630.94 1,693.66 62.71
It has been submitted by the petitioner that as per Regulation 8.3.4 of HERC MYT Regulations
2019, expenditure towards terminal benefits are uncontrollable items. The petitioner has,
therefore, submitted that actual expenses toward terminal benefit may be allowed in the truing
up of ARR of UHBVNL for FY 2022-23 and the actual O&M Expenses as per the audited accounts
of UHBVNL for FY 2022-23 are Rs. 1693.66 Crore. UHBVNL further requested that O&M expenses
incurred on actual basis may kindly be allowed to them for FY 2022-23.

The Commission has examined the calculations of true up for the FY 2022-23 proposed by
UHBVNL and observes that the total O&M expenditure, as per actuals, is largely within the
approved amount except for the Administration & General Expenses and terminal liabilities. It
is also observed that R&M expenditure incurred by UHBVNL is on the lower side. It is further
observed that the actual A&G expenses for the FY 2022-23 is more than that approved by the
Commission i.e. A&G expenses have increased by Rs 86.30 crore in the true-up year.

The petitioner, as part of additional information vide letter No. Ch-82/RA/F-25/Vol-84 dated
11.01.2024, submitted that the increase in A&G expenses is mainly due to Consultancy charges
Rs 11.59 Crore, Technical Fees Rs 34.87 Crore, Annual License Fees to HERC Rs 3.31 Crore and

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

refund of penalty already deducted of Rs 7.68 Crore. The reason for increase in terminal benefits
is the calculation made by the actuary on the basis of assumption i.e. Discount rate @ 7.5%,
Basis salary growth @ 3.5% PA, DA/DR Growth rate @ 6.5% Compound, Expected rate of on plan
assets etc. Further, it is stated that it can be presumed the difference is due to new requirement
of New Employees/ Transfer from DHBVNL/ UHBVNL etc. It implies that Terminal benefit liability
is booked as per actuarial valuation report. The Commission has sought details of Legal/
Professional/ Consultancy expense /Technical fees, Service charges for Training/ Meter Reading
/ Bill Distribution/ Bijli Suvidha Kendra, Commission charges on collection of Energy Bills, other
expenses, and Material related Exp from the Nigam, which has been provided by UHBVNL vide
letter No. Ch-98/RA/F-25/Vol-84 dated 30.01.2024 as under:-

Coding Description Amount (Rs.)

23.15 Professional Charges. 8864761
Legal charges. 70138247
Audit fees. 2986812
Consultancy charges. 124936221
Technical fees. 557827404
Total (Legal /Prof./Consultancy Exp/Tech Fees 764753445
23.22 Charges for computerization. 80361598
Training Expenditure 1686497
Service charges for meter reading. 224215523
Service charges for bill distribution 88833605
Expenditure for Providing Bijli Suvidha Kendra 27330839
Total (Service Charges for Training/Meter Reading/Bill Distribution/ Bijli Suvidha Kendra 422428062
23.32 Commission charges on collection of Energy Bills 8,00,80,369
23.34 Directors sitting Fees 285000
Expenditure of sports activity organized by the Nigam 7427124
Payment of testing/checking and sealing of meters to contractor 8784813
Miscellaneous expenses. 41110248
Expenditure for the Air Conditioner Replacement program for DS Consumers of UHBVNL 2933373
Expense on Ujjawal Bharat Bhavishya, Power @2017 under Azadi ka Amrit Mahotsav 1565863
CSR Expense (on FY 2019-20 Balance Sheet) 16050891
Expenses for up-dation of delta changes in Geographical Information System (GIS) 36847480
GST Expenditure (Reverse Charge Mechanism) 5715668
Expense Against Refund of Penalty and others 99260966
CSR Expense (on FY 2020-21 Balance Sheet) 5884265
Total (Other Expense) 225865690
23.35 Other freights 17271324
Incidental stores expenses 12146155.19

Total (Material related Exp.) 29417479

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Based on the explanation for the additional expenditure on this account provided by UHBVNL,
being “controllable expenditure” as per the HERC MYT Regulations in vogue, the Commission
disallows the same and restricts A&G expenses to the extent approved vide order dated
30.03.2022 i.e. Rs 86.30 crore to be disallowed. Further, Terminal Liabilities, being an
“uncontrollable item”, the Commission approves the true up of O&M expenditure as proposed
by the licensee, amounting to Rs 543.25 crore.
On this issue of A & G Expenses, almost 39.30 crore is towards meter reading, Commission
charges on collection of energy bills, testing, sealing, checking of meter etc. Additionally, a
whopping Rs. 7.01 crore was spent on legal fee, 12.49 crore on consultancy charges. Per se
their amount appears to be exorbitant and needs to be reviewed and reined in. No such
expenses ought to be undertaken by the licensee without establishing the benefit stream viz
value addition.
The petitioner may note that necessary compliance of Hon’ble Supreme Court’s directions in
its judgment dated 20.04.2023 in Civil Appeal No. 11095 of 2018 passed in GMR Warora Energy
Ltd. Versus CERC and Ors is done. The Apex Court in their order had directed those non-
essential litigations needs to be avoided and emphasized on requirements of timely payment
of dues. They have further observed that the Haryana Utilities had been adopting dilatory
tactics which not only defeats the public policy but also has the undesirable fall out of adding
to the burden of the end-consumers and stated that such practice needs to be curbed. The
Hon’ble Court reiterated that the ‘Change in Law’ events will have to accrue from the date on
which Rules, Orders, Notifications are issued by the instrumentalities of the State and despite
this, Discoms are pursuing litigation after litigation.
As against the slippages in the A & G expenses which has no direct benefit to the electricity
consumers, the Commission observes that an essential expenditure i.e. R & M, which is
required to keep the distribution system in an optimum condition, has fallen short of even the
amount approved by the Commission.
In view of above, Nigam is advised to avoid unnecessary and unwarranted litigation to ensure
development of the power sector and supply of electricity and efforts should be made to
resolve amiably inter-utility issues. As directed by the Hon’ble Supreme Court, any appeal to
it can only be on substantial question of law and frivolous litigation needs to be discouraged.

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The R&M activity needs to b pursued in the right earnest as it will go a long way in making
available quality supply of power to the electricity consumers of Haryana.
The Discoms (UHBVNL and DHBVNL) are directed to claim the actual terminal liabilities instead
of the same based on ‘actuarial valuation’, which has shown large year to year variation casting
doubts on the underlying assumptions. The approved O&M expenditure for UHBVNL is listed
as under: -
(Rs. Crore)
Particulars Approved for FY Actual for FY Difference Approved
2022-23 in T.O. 2022-23 (C=B-A)
dt. 30.03.2022
Employee Expenses 859.4 857.53 -1.87 857.53
Administration & General Expenses 112.85 199.15 86.3 112.85
Repair & Maintenance Expenses 158.69 93.72 -64.97 93.72
Terminal Liabilities 500 543.25 43.25 543.25
Total 1,630.94 1,693.66 62.72 1607.35

True-up proposed by DHBVNL:

The component wise summary of actual and approved O&M expenses of DHBVNL for FY 2022-
23 is tabulated as under is as reproduced below: -

O&M Expenses for FY 2022-23 (Rs. Crore)

Particulars Approved (A) Actual (B) Difference (B-A)

Employee Expenses 1,072.88 984.89 -87.99
Administration & General Expenses 145.77 160.74 14.97
Repair & Maintenance Expenses 194.43 131.06 -63.37
Terminal Liabilities 442.90 697.77 254.87
Total 1,855.98 1,974.46 118.48
DHBVNL has submitted that the actual net employee cost for FY 2022-23 is lower than the HERC
approved employee cost, therefore, the licensee has requested the Commission to allow the
actual employee expense. Further, the Nigam has submitted that the actual R&M expenses for
the FY 2022-23 is lower than approved and therefore, requested the Commission to allow actual
R&M Expenses in line with the audited accounts.

The actual O&M Expenses as per the audited accounts of DHBVNL for the FY 2022-23 is higher
than the allowed expenses to DHBVNL in Tariff Order dated 30.03.2022. Therefore, the petitioner
Nigam has prayed that O&M expenses incurred on actual basis may be allowed for the
FY 2022-23.

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The Commission has examined the true up for the FY 2022-23 proposed by DHBVNL and
observes that the total O&M expenditure as per actuals is higher than that approved by the
Commission for the year, except for Employee Expenses and R&M expenses.

Regarding increase in O&M, DHBVNL has submitted that such variation in actual O&M expense
is mainly due to increased terminal liability which is uncontrollable in nature and Terminal
benefit in True-up of FY 2022-23 is claimed on actual basis as per Audited Accounts. Further,
the reasoning for increase in A&G expenses i.e. Rs 14.97 crore is not justifiable and needs to
be reined in. The petitioner, as part of additional information (letter No. Ch-110/SE/RA-772
dated 18.12.2024), submitted that the increase in A&G expenses is mainly due to the increase
in Legal charges, Consultancy charges, license fee, billing distribution charges, Bijili Suvidha-
Kendra and Expenditure on computerization. Such expense is vital part of electricity
distribution business and same are requested to be allowed on actual basis. Variation in
Terminal Liability is mainly on account of re-valuation of gains/(loss) of defined benefit plans.

The Commission disallows the true up of A&G expenses as proposed by the licensee to the
extent of Rs 14.97 Crore and allows the ‘Terminal benefits’, as they are “uncontrollable
expenses” as per the MYT Regulations, 2019. However, the distribution licensee is directed to
pursue R&M activity in the right earnest as it will go a long way in making available quality
supply of power to the electricity consumers of Haryana. Further, the Nigam is directed to
claim the actual terminal liabilities instead of the same based on ‘actuarial valuation’, which
has shown large year to year variation casting doubts on the underlying assumptions.
The distribution licensees are expected to avoid unnecessary and unwarranted litigation to
ensure development of the power sector and supply of electricity and efforts should be made
to resolve amicably inter-utility issues. As directed by the Hon’ble Supreme Court, any appeal
can only be on substantial question of law and frivolous litigation needs to be discouraged.
The approved O&M expenditure for DHBVNL is listed as under: -
(Rs. Crore)
Particulars Approved Audited/Actual Difference (B-A) Revised
(A) (B) approved
Employee Expenses net of 1,072.88 984.89 -87.99 984.89
capitalization
Administration & General 145.77 160.74 14.97 145.77
Expenses
Repair & Maintenance Expenses 194.43 131.06 -63.37 131.06
Terminal Liabilities 442.9 697.77 254.87 697.77
Total 1,855.98 1,974.46 118.48 1959.49

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

3.3 Depreciation
UHBVNL
The Commission observes that vide order dated 30.03.2022, it had approved Rs. 414.53 Crore
expenditure towards depreciation to UHBVNL for FY 2022-23. Further, on perusal of the audited
accounts of the Nigam, gross depreciation amounting to Rs. 461.04 Crores is calculated based on
Opening & Closing GFA of Rs. 9,462.70 Crore and Rs. 9,923.66 Crore respectively. As per the MYT
regulations in vogue, net expenditure towards depreciation amounts to Rs. 374.60 Crore for
UHBVNL in FY 2022-23, after adjustment of depreciation on the assets created from consumer
contribution and grants (amounting Rs. 86.43 Crores).
As the actual expenditure towards depreciation is less than the expenses approved for UHBVNL
for FY 2022-23 in the Tariff Order dated 30.03.2022. Accordingly, the Commission approves the
actual expenditure toward depreciation as per the audited accounts i.e. Rs 374.60 crore, as
proposed by the UHBVNL for the FY 2022-23.
DHBVNL
The Commission observes that vide order dated 30.03.2022, depreciation of Rs. 446.92 Crore for
FY 2022-23 was approved by the Commission vide its Tariff Order dated 30.03.2022. Further, as
per the Audited Accounts for FY 2022-23, gross depreciation works out as Rs 513.42 Crore. The
gross depreciation is adjusted for the depreciation on account of the assets created out of
consumer contribution and grants amounting to Rs. 165.67 Crore. Consequently, net
depreciation works out to Rs. 347.75 Crore during the FY 2022-23.
As the actual expenditure towards depreciation is lower than the expenses approved for DHBVNL
for FY 2022-23 in the tariff order dated 30.03.2022, the Commission allows actual expenditure
toward depreciation for FY 2022-23 amounting to Rs 347.75 Crore, after adjustment of
depreciation on the assets created from consumer contribution and grants.

3.4 Interest on Consumers Security Deposit

UHBVNL:
The Commission, vide ARR order dated 30.03.2022, had approved interest on consumer security
deposits as Rs. 69.71 Crore for UHBVNL for FY 2022-23. It is observed that actual expenditure of
UHBVNL as per its audited accounts is Rs. 61.64 Crore for the FY 2022-23. In view of audited
accounts, the Nigam has requested that the actual expense towards interest on consumer
security deposit may be approved for UHBVNL for FY 2022-23.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL:
Similarly, it has been submitted that the Hon'ble Commission, vide its Tariff Order dated
30.03.2022, had approved Rs. 86.64 Crore as interest on consumer security deposit for FY 2022-
23. However, the actual expenses incurred is Rs. 64.33 Crore during FY 2022-23, which is lower
in comparison to the approved interest on consumer security deposit. Therefore, DHBVNL has
requested that the Commission may approve the actual interest on consumer security deposit
to DHBVNL for the FY 2022-23.
In view of above submissions, the Commission observes that the actual expenditure of both
the Discoms, is lower than that allowed by the Commission in its ARR Order for the FY 2022-
23, and is therefore, approved for true- up.

3.5 Interest on Capex loans

UHBVNL
The Commission observes that UHBVNL has incurred Expenditure on capital works (CAPEX)
amounting to Rs. 743.82 Crores as per the audited accounts of the FY 2022-23 as against Rs. 970
Crores approved by the Commission in the Tariff Order dated 30.03.2022 for the FY 2022-23.
The Nigam, in its petition, submitted that the Commission has allowed Rs. 159.61 Crore to
UHBVNL towards the interest liability on long term loans for FY 2022-23. The actual expense as
per the audited accounts of UHBVNL is Rs. 249.84 Crores (CAPEX loan) on gross basis and on
adjustment of interest capitalized of Rs. 35.82 Crore, the net interest liability towards long term
loans is Rs. 214.02 Crore. However, the above-mentioned figures were amended by the
petitioner in its reply to the additional information sought by the Commission. The details are
reproduced in the upcoming paragraphs.
The Commission has examined the interest cost actually incurred by the licensee during the FY
2022-23 as against that approved by the Commission. At the onset, the Commission observes
that the Nigam should not divert the short-term funds for the long-term purposes and vice versa.
There were certain set of figures in the petition bifurcating the interest component and the same
was replaced with another set of figures in the additional information filed in the Commission
vide Memo no Ch-82/RA/F-25/Vol-84 dated 11.01.2024. UHBVNL in the additional information
submitted the bifurcation details of interest cost as per the audited account into long term Capex
loan & Working Capital loan and Institutions wise Borrowings. The reason for the increase in
interest cost of Capex loan of FY 2022-23 from Rs. 133.40 crore (FY 2021-22) to Rs. 185.64 crore

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

was stated to be the increase in the rate of interest of the banks / Financials Institutions and due
to drawl of additional Capex loan of Rs. 427.55 crore during FY 2022-23. The Nigam further stated
that interest of Rs 84.02 crore on term loan was inadvertently included as part of Interest on
Capex loan in Table 13 (Total Interest & Finance Charges for FY 2022-2023) of ARR petition. And
requested the Commission to consider the interest of Rs 84.02 crore on term loan as part of
interest on working capital loan instead of Capex loan for FY 2022-2023.
Additionally, vide letter No. Ch-98/RA/F-25/Vol-84 dated 30.01.2024, UHBVNL has submitted
that Nigam has taken working capital loans for a tenor of 10 to 15 Years (long term) as such same
has been classified under the long-term borrowing in the audited account.
The Commission observes that the above classification of term loan into working capital loan
will invariably create a mismatch of funds repayment issue, which will impact the working
capital and business sustainability. Accordingly, the actual interest cost of Rs 130.86 crore,
after deducting the interest capitalized is approved for true up for the FY 2022-23. UHBVNL is
directed to file the petition after prudence check and as per the facts, in line with the audited
accounts. Any true up claims in variance with the audited accounts will not be considered.
DHBVNL
The Commission observes that Capital Expenditure (CAPEX) allowed to DHBVNL, as per the Tariff
Order dated 30.03.2022, was Rs. 1380.00 Crore for FY 2022-23. As per the audited accounts,
DHBVNL has incurred capital expenditure of Rs. 1,120.15 Crore for FY 2022-23.
DHBVNL, in its petition, has submitted that as per the Audited Accounts the gross interest liability
towards long term borrowing is Rs. 259.39 Crore. After adjusting interest capitalization of Rs.
124.16 Crore, the net interest cost of DHBVNL on long-term loans works out as Rs. 135.23 Crore
for FY 2022-23. The Commission, vide its Tariff Order dated 30.03.2022, has allowed Rs. 200.44
Crore to DHBVNL towards the interest liability on long-term borrowing for FY 2022-23. DHBVNL
has prayed that the Hon’ble Commission may allow actual interest cost on long-term borrowing
to DHBVNL for FY 2022-23.
Additionally, DHBVNL vide letter No. Ch-110/SE/RA-772 dated 18.12.2024 has submitted that
the interest rate on Loan from Financial Institutes and Bank are linked to marked based Lending
rate i.e. MCLR, REC Lending Rate, LIBOR, which has varied significantly during FY 2022-23.
As the actual interest of DHBVNL on long term borrowing is lower than the amount approved
by the Commission in Tariff Order dated 30.03.2022 and is in line with actual capital

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

expenditure and its funding thereto; the Commission approves the actual interest cost incurred
on long term borrowing by DHBVNL i.e. Rs. 135.25 crores for FY 2022-23 on true up.

3.6 Interest on Working Capital Loan

UHBVNL:
UHBVNL, in its petition, has submitted that the Commission had approved interest cost on
working capital on normative basis. Interest cost on working capital in actual is Rs. 109.56 Crs
against Rs. 71.94 Crores allowed for FY 2022-23. As stated in above paras, UHBVNL has revised
the bifurcation of the interest component of loans into capex and working capital. As per the
revised submissions, the interest on working capital proposed by the licensee is Rs 205.01 Crore.
Interest cost on working capital as per the audited accounts is higher than the allowed cost to
UHBVNL for FY 2022-23 in the Tariff Order dated 30.03.2022. It is submitted that higher power
purchase cost led to a higher quantum of Working Capital loans from banks. It has been averred
that the interest cost for working capital loan also rose significantly, resulting in higher working
capital interest cost. UHBVNL has prayed that the Hon’ble Commission may allow the actual
expenditure for truing up of ARR of UHBVNL for FY 2022-23. The reasons cited for increase in
interest cost of working capital loan during FY 2022-23 is the increase in the rate of interest of
the banks / Financials Institutions.
During the FY 2022-23, it is observed that UHBVNL has borne interest cost of Rs 11.42 Cr towards
HVPN Bonds. Besides the above, the Commission has retained the working capital borrowings to
the normative or actual level, whichever is lower. The interest cost on borrowings which are not
part of the expenses to be allowed as per MYT Regulations are to be treated in accordance with
the relevant order of the Commission i.e. the order dated 30.03.2022, therefore, interest on
HVPNL bonds have been not allowed and considered as part of actual interest. The Commission
allows the normative interest on working capital, being lower than the actual interest i.e. Rs
130.86 crore.
(Rs. Crore)
FY 2022-23
Interest on working capital Order dt. 30.03.2022 Revised True up

O&M expenses for 1 month 135.91 133.95

Maintenance spares 1% of opening GFA 98.46 94.63
2 months receivables 2231.39 3021.23
Uncollected revenue 66.94 90.64
Total 2532.70 3340.44

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

FY 2022-23
Less
ACD 1686.37 1576.32
Net working capital 846.33 1764.12
Interest rate 8.50% 7.41%
Interest cost 71.94 130.65
DHBVNL:
The Commission, vide its Tariff Order dated 30.03.2022, has approved interest cost on working
capital as Rs 104.94 Crore for FY 2022-23. Based on the revised ARR submitted in the current
petition, the normative working capital requirement has been worked out by DHBVNL in line
with the provision of Regulation 12 of HERC MYT Regulations, 2019. Normative Interest on
working capital has been computed as Rs. 217.12 Crore for FY 2022-23 by DHBVNL.

The working capital requirement of DHBVNL in FY 2022-23 has increased significantly, as

compared to the working capital requirement approved by the Commission in Tariff Order dated
30.03.2022. Such variation in working capital requirement is mainly due to higher outstanding
receivables for sale of power to the electricity consumers. However, as per the Audited Accounts,
actual interest cost on working capital for FY 2022-23 is Rs. 127.26 Crore, which is lower than the
normative interest on working capital. Accordingly, the Nigam has requested to allow the actual
interest on working capital to DHBVNL for FY 2022-23.

Further, DHBVNL has borne the interest cost of Rs 11.42 Crores on HVPNL bonds. As against
approved Interest on working capital borrowings amounting to Rs. 104.94 crores, DHBVNL has
incurred an expenditure of Rs.127.26 crores during the FY 2022-23. The actual interest cost, after
disallowing the interest on HVPNL bonds, amounts to Rs 115.835 Crore. The Commission has
examined the same and finds the cost incurred as reasonable; accordingly approves the same for
true up, as the normative interest calculations are higher than the actual interest cost.
Accordingly, the Commission allows the actual interest on working capital, being lower than
the normative interest i.e. Rs 115.835 crore (127.26-11.42).

3.7 Total Interest Expenses including cost of raising Finance and Bank Charges
The Commission had allowed Rs 34.90 crore as expenditure towards cost of raising finance and
bank charges to UHBVNL and Rs. 34.92 Crores was allowed to DHBVNL as proposed by both the
Discoms. As per the audited accounts, UHBVNL has incurred a cost of Rs. 24.98 Crore while

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL has incurred Rs. 35.8 Crore on this account. As it is a cost required for raising the
requisite funds, the Commission allows the same to be trued up.
Interest and finance charges incurred as per the audited accounts of UHBVNL for FY 2022-23 is
lower than the amount approved in Tariff Order dated 30.03.2022.
Summary of interest and finance charge approved and actual as per the audited accounts of
UHBVNL and DHBVNL for the FY 2022-23 is tabulated as follows:
Approved Total Interest & Finance Charges of UHBVNL for FY 2022-23 (Rs Crores)
Sr. No. Category Approved Proposed Revised proposed Approved
for FY 2022- by by UHBVNL vide during
23 in T.O. UHBVNL in letter dated true up
dt. petition 11.01.2024
30.03.2022
1 Gross Interest on Capex Loans 159.61 249.84 166.68 166.68
2 Less: Interest Capitalized - 35.82 35.82 35.82
3 Net Interest on Capex Loans 159.61 214.02 130.86 130.86
4 Interest on Working Capital 71.94 109.56 205.01 130.65
Loans
5 Interest on Consumer 69.71 61.64 61.64 61.64
Security Deposits
6 Other Interest and Finance 34.90 24.98 24.98 24.98
charges / Guarantee Fees
7 Total Interest and Finance 336.16 410.21 422.49 348.13
Charges

Approved Total Interest & Finance Cost of DHBVNL for FY 2022-23 (Rs Crore)
Sr. No. Category Approved Actual Revised Approved
1 Gross Interest on Capex Loans 307.32 259.39 259.39
2 Less: Interest Capitalized 106.88 124.16 124.16
3 Net Interest on Capex Loans 200.44 135.23 135.23
4 Interest on Working Capital Loans 104.94 127.26 115.83
5 Interest on Consumer Security 86.64 64.33 64.33
Deposits
6 Other Interest & Finance Charges 11.00 23.58 23.58
7 Guarantee Fee 24.00 12.22 12.22
8 Total 427.02 362.62 351.18
3.8 Expenditure due to other debits
UHBVNL:
As per the audited accounts, Rs. 9.94 Crore has been the actual expenditure of UHBVNL towards
other debits in FY 2022-23. The expenditure mainly include compensation paid for injury, death,
or damage and other expenses written off. The Nigam has prayed that the expenditure towards
other debits may be allowed for FY 2022-23.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Further, UHBVNL vide letter No. Ch-82/RA/F-25/Vol-84 dated 11.01.2024, submitted that the
following amount has been included in Rs 631.49 Lakhs:
• Miscellaneous losses and ‘Written Off’ of Rs 462.50 Lakhs which includes write off value of
theft of transformers and write off Misc. advances.
• Loss in sale of Scrap of Rs 169 Lakhs
Apart from the Compensation for Injury, death, damage and penalty, the Commission observes
that items ‘Miscellaneous losses’ and written off are not eligible to be included in the ARR for
true up; as the same are losses. In light of the above discussion, the Commission approves
Rs.3.62 Crores as true up of other debits for UHBVNL for the FY 2022-23 as stated below:
Approved- Other debits of UHBVNL for FY 2022-23 (Rs. Crore)
Particulars Proposed as per Approved
Audited Accounts
Provision for Bad & Doubtful Debts - -
Bad & Doubtful debts written off under Bill Settlement Scheme - -
Compensation for Injury, death, damage and penalty 3.63 3.63
Infructuous Capital Exp. Written off - -
Loss on Obsolescence of Stores/ Scrap & Assets - -
Loss on exchange rate variation - -
Miscellaneous losses written off 6.31 -
Provision for amount recoverable from employees/theft of - -
property
Total Expenses 9.94 3.63

DHBVNL:
As per the audited accounts, Rs. 17.67 Crore has been incurred by DHBVNL as Other Debits during
FY 2022-23. The major portion of Rs. 17.67 Crore consists of expenditure on account of
compensation, miscellaneous losses etc. which are normal in the business of power distribution
hence the DHBVNL requested to allow other debits in terms of applicable HERC MYT Regulations,
2019.
The Commission has examined the above “other debits” and observes that though
Compensation for injuries, death & Damage may form part of allowable true up, no provisions
or miscellaneous losses/ write off can be allowed to be passed on to the consumers. Therefore,
the proposed amount of other expenses of DHBVNL are disallowed, as per below details:

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Approved- Other debits of DHBVNL for FY 2022-23 (in Rs. Crore)

Other debits
As per audited- details provided Proposed Allowed
Refund of Revenue other than A.P. 0.00 0.00
Shortages on physical verification of stock. 1.54 0.00
Loss of materials by pilferage etc. 0.36 0.00
Compensation for injuries, death & Damage‐staff 2.56 2.56
Compensation for injuries, death & Damage‐Outsiders 5.81 5.81
Misc. Compensations. 0.52 0.00
Loss on sale of fixed Assets 6.33 6.33
Sundry debit balances written‐off. 0.09 0.00
Loss on account of Shortage & breakage of damaged distribution Transformer 0.47 0.00
Total 17.67 14.70

3.9 Return on Equity (RoE)

UHBVNL:
UHBVNL has submitted that the Commission had allowed Rs. 250.33 crore as Return on Equity
to the Nigam for the FY 2022-23 in order dated 30.03.2022.
In view of above, UHBVNL has prayed that in consideration to the higher operational efficiency
and reduction of 3.64% distribution losses achieved by UHBVNL in FY 2022-23, Return on Equity
as per the prevalent regulations may be allowed to petitioner.
The Commission has approved the closing equity as on 31.3.2022 as part of the ARR Order dated
15.02.2023 and the same shall form the basis of calculation of RoE for the FY 2022-23. The
opening balance shall be increased by the equity contribution i.e. 20% relating to the assets
added during the year, as per information provided by the licensee and audited accounts. The
rate of return is the same as approved by the Commission as per the Order dated 30.03.2022,
the same cannot be varied at the stage of ‘truing up’ exercise.
As per Regulation 20 of the HERC MYT Regulation 2019, Return on Equity has been approved as
under: -
Approved Return on Equity of UHBVNL for 2022-23 (Rs Crores)
Particulars Proposed Approved
Eligible Opening Equity 2,310.97 2,310.97
Add: Equity corresponding to capitalized assets (excl. assets from 144.27 74.94
consumer contribution)
Closing Equity 2,455.24 2385.91
Average Equity for RoE 2,383.11 2348.44
Rate of RoE 10% 10%

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Particulars Proposed Approved

Total RoE 238.31 234.84
DHBVNL:
DHBVNL has submitted that the Commission, in Tariff Order dated 30.03.2023, has allowed RoE
of Rs. 236.75 Crore to DHBVNL for FY 2022-23.
DHBVNL has considered opening equity balance of FY 2022-23 as Rs. 2047.04 Crore. The DHBVNL
has infused Rs 139.82 Crore equity during the FY 2022-23. As per the Regulation 20 of HERC MYT
Regulation 2019, Return on Equity has been calculated for FY 2022-23 and prayed that in
consideration to the operational efficiency achieved in FY 2022-23, Return on Equity as per the
prevalent regulations, may be allowed to the petitioner.
The Commission has approved the closing equity as on 31.3.2022 as part of the ARR Order dated
15.02.2023 and the same shall form the basis of calculation of RoE for the FY 2022-23. The
opening balance shall be increased by the equity contribution i.e. 20% relating to the assets
added during the year, as per information provided by the licensee and audited accounts. The
rate of return is the same as approved by the Commission as per the Order dated 30.03.2022
and at this stage, the rate of return per se cannot be varied.
As per the Regulation 20 of the HERC MYT Regulation 2019, Return on Equity has been approved
as under: -
Approved Return on Equity for FY 2022-23 for DHBVNL (Rs Crore)
Particulars Proposed Approved
Opening Equity for Return on Equity 2047.04 2047.04
Add: Equity received for Capitalization 139.82 93.21
Closing Equity 2,186.86 2,140.25
Average Equity eligible for Return on Equity 2,116.95 2,093.65
Rate of Return on Equity 10% 10%
Return on Equity 211.695 209.365
3.10 Non-tariff Income
UHBVNL
Actual, as per the audited account, the Non-Tariff income of UHBVNL for FY 2022-23 is Rs. 116.27
Crores as against Rs. 221.56 Crore approved by the Commission in Tariff Order dated 30.03.2022.
UHBVNL has not considered the delayed payment surcharge, rebate on timely payment of energy
charges and early payment rebate from suppliers/contractors as part of non-Tariff income for FY
2022-23.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

It has been submitted that income on account of delayed payment surcharge is to be adjusted
towards the working capital that must be borne by the Distribution Licensee due to non-
collection of energy bill in timely manner from the consumer. Therefore, the same has been
deducted from Non-Tariff Income of UHBVNL for FY 2022-23.
Rebate received on timely payment of energy charges and early payment rebate from
suppliers/contractors is also not considered as a part of non-tariff income for FY 2022-23. It is
submitted that interest cost on working capital loan is allowed on normative basis, whereas
additional short-term borrowing is to be arranged by UHBVNL to avail the rebate on timely
payment of energy charges and to suppliers/contractors. Therefore, to meet the interest liability
of additional working capital requirements, rebate on timely payment of energy charges and
timely payment to suppliers/contractors is being used by UHBVNL to balance the actual working
capital cost implication on the Discoms. In light of the above, the Commission approves true up
of Non-tariff Income at Rs. 116.27 crores as proposed by UHBVNL.
DHBVNL

Actual Non-Tariff income of DHBVNL for FY 2022-23 is Rs. 267.52 Crore against Rs. 307.66 Crore
approved by the Commission in Tariff Order dated 30.03.2022.

DHBVNL has not considered the delayed payment surcharge & timely payment of energy charges
and Supplier/ Contractor as part of Non-Tariff income for FY 2022-23. It has been submitted that
income on account of delayed payment surcharges Rs. 289.50 Crore is to be adjusted towards
the working capital which has been borne by the Distribution Licensee due to non-payment of
energy bill in timely manner by the consumer. Therefore, the same has been deducted from Non-
Tariff Income of DHBVNL for FY 2022-23.

Further, rebate received on timely payment of energy charges is also not considered as a part of
non-tariff income for FY 2022-23. It is submitted that interest cost on working capital loan is
allowed on normative basis, whereas additional short-term borrowing is to be arranged by
DHBVNL to avail the rebate on timely payment of energy charges and to suppliers/contractors.
Therefore, to meet the interest liability of additional working capital requirements, rebate on
timely payment of energy charges and timely payment to suppliers/contractors is being used by
DHBVNL to balance the actual working capital cost implication on the Discoms.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Non-Tariff Income - DHBVNL for FY 2022-23 (Rs Crore)

Particular Approved HERC Approved
Non-Tariff Income 639.81
Less: Delayed Payment Surcharge from Consumer 307.66 289.50
Less: Discount on timely payment of Energy Charges 82.79
Net Non-Tariff Income 307.66 267.52

In light of the above, the Commission approves the true up of Non-tariff Income at Rs. 267.52
crores as proposed by DHBVNL.

3.11 True-up of Power Purchase Quantum & Cost

The Commission observes that the difference in power purchase cost could arise either on
account of variation in actual source wise generation or rate of power vis-à-vis those allowed by
the Commission on a projected basis. Any deferral in allowing power purchase cost to the
Distribution Licensee on account of additional power purchase expenditure, results in accrual of
additional burden in form of interest cost (carrying cost), which as the Distribution Licensee will
have to ultimately resort to funding through short-term loans. Such a measure is not in the
interest of the consumers as there is an additional burden in terms of higher tariff on the
consumers. Therefore, timely and regular pass through of variations in power purchase cost is
not only imperative for optimum financial management of the Distribution Licensee but is also
imperative from the consumers’ standpoint as the cost and price of delivered power ought to
remain aligned.
As per the MYT Regulations 2019, the Discoms are allowed to automatically recover FSA, without
going through the regulatory process subject to a cap, in order to ensure financial viability of the
licensees. However, the automatic recovery is subject to a cap and therefore the need to True-
up arises. Also, the actual cost for the year can only be determined after the audited accounts
are available. In view of the aforesaid constraints, the actual power procurement cost is to be
trued up based on the normative distribution losses approved by the Commission in the ARR /
Tariff Order for the relevant year. Transmission losses are allowed as per actual since the Discoms
have no control over the transmission losses. Further, in light of the fact that AP sales in the state
are unmetered and even the metered supply due to large number of dead / defective meters are
not accurate, the Commission is constrained to arrive at an estimate of AP sales based on the
energy recorded at the 11 kV AP segregated feeders. The Commission estimates and approved

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

AP sales are discussed at section 5.2 of this order and has a major impact on the distribution loss
levels of the Discoms, in the FY 2022-23. Based on the approved AP sales and the distribution
loss level approved by the Commission in its Order dated 30.03.2022, the excess units purchased
by the Discoms is arrived at and treated in terms of the incentive and penalty mechanism of the
HERC MYT Regulations, 2012. However, during the true up of power purchase, no units have
been disallowed.
Details of prior period expenses provided vide letter No. Ch-98/RA/F-25/Vol-84 dated 30.01.2024
by UHBVNL is as under:

Project Name UHBVNL Share Reply

(Rs Crores)
HPGCL 42.93 Crores 1(a) An amount of Rs. 153.09 crores is related to the
[(103.82 Crore – payment made on accounts of Coal quality claim
60.89 Crores (DHBVNL) = raised by Coal Companies i.e., ECL, WCL, NCL, MCL &
42.93 Crores (UHBVNL))] CCL pertaining to prior period to HPGCL & Fuel Price
Adjustment of Secondary fuel Oil (in compliance of
HERC order dated 25.01.2023). HPGCL has raised the
said claim for reimbursement vide invoice as under:
Month Invoice Amount (in Crores)
6/22 121.05
1/23 24.40
2/23 7.64
Further, HPGCL vide its office memo dated
08.06.2022 has justified the said claim that the claims
(debit notes) are issued by coal companies due to
variation of declared grade & analyzed grade of coal.
HPGCL further intimated that claims (debit notes) are
raised by coal companies if quality grade analyzed by
CIMFR is better than that of declared grade of coal.
(b) Hon′ble Commission vide its order dated 25.01.2023
has allowed Rs. (-)49.50 crores true-up expenses for
the FY 2021-22 and Discoms recovered the aforesaid
amount of Rs. 49.50 crores from HPGCL.
Accordingly, a net prior period expense of Rs. 103.82 Crore
(i.e., Rs. 153.09 Crore – 49.50 Crore) is claimed under the
head of HPGCL.
LPS (LPS paid 530.84 Crores 2(a) The LPS of prior period expenditure amounting to Rs.
to Adani [(1291.57 Crore – 760.73 1081.61 Crores was mainly relating to Adani Power
Power Ltd. Crores (DHBVNL) = limited. APL approached to CERC in 2012 for
amounting to 530.84 Crores compensation on account of shortfall in domestic
Rs. 1291.57 (UHBVNL))] coal under Change in law (CIL). CERC vide order
Crores. dated 21.02.2014) allowed compensation under CIL.
Thereafter, HPPC challenged the ibid compensation
order at various Courts. Ultimately, Hon’ble
Supreme Court of India (SCI) vide order dated
20.04.2023) upheld the CERC decision. As per ibid

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

order, APL has raised the invoice amounting to Rs.

2220 crores on account of shortfall in domestic coal
under CIL for FY 2013 – 2021 along with carrying cost
& LPS. The same amount has been paid after getting
approval from Government of Haryana.APL′s claims
to the tune of Rs. 209.96 crores approx. inclusive of
late payment surcharge relating to the taxes &
duties pursuant to the APTEL order dated
21.12.2021.

The Commission observes that prior period expenses are legitimate charges arising from claims
of Coal India Limited and its subsidiaries as well as statutory order. Hence, the same are being
allowed as proposed subject to adjustment if required. Based on the data provided by the
Discoms and taking into consideration the audited accounts, the details of True-up of power
purchase cost of the Discoms for the FY 2022-23 is as per the table below:
Approved True-up of Power Purchase Cost (FY 2022-23)
Particulars UHBVNL DHBVNL Total
Sales as per audited accounts MU 21,654.66 31,008.28 52662.94
Less AP sales included in above MU 4,036.91 6,147.31 10184.22
Sales as per audited accounts (net of AP sales) MU 17,617.75 24,860.97 42,478.72
Add AP sales as per HERC methodology MU 4,036.91 5,604.79 9,641.70
Approved/Audited sales adjusted for AP MU 21,654.66 30,465.76 52,120.42
Approved Distribution losses MU 14.00% 14.00% 14%
Sales grossed up for Distribution losses MU 25,179.84 35,425.30 60,605.14
Actual Interstate sales and banking MU 705.17 1,076.89 1,782.06
Total power sold including inter-state sale and MU 25,885.01 36,502.19 62,387.20
banking
Intra state transmission losses 2.05% 2.05%
Sales grossed up for Intrastate transmission MU 26426.76 37266.15 63,692.90
losses
Intra state transmission losses MU 541.75 763.96 1305.70
Intrastate & Interstate transmission losses as per MU 950.36 1401.241 2351.601
audited accounts
Interstate transmission loss MU 408.61 637.28 1045.90
3.54% 3.70%
Approved power purchase volume (Sales grossed MU 26,835.37 37,903.43 64,738.80
up for Intrastate & Interstate transmission losses)
Actual Power Purchase Volume MU 25,803.26 37,482.95 63,286.21
Disallowed Units MU -1,032.11 -420.49 -1,452.59
Disallowed Units MU 0.00 0.00 0.00
Actual cost incurred by DISCOMs during the FY Rs. Crore 15675.12 22480.37 38,155.49
2022-23 (incl HVPNL and SLDC charges)
Net power purchase cost admitted by the Rs. Crore 15675.12 22480.37 38,155.49
Commission
Allowed Average per unit rate 5.84 5.93 5.89

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Particulars UHBVNL DHBVNL Total

Power purchase cost allowed in the ARR order
30.03.2022
Approved power purchase cost (incl Rs. Crore 10977.94 15110.942 26,088.88
Transmission & SLDC)
Approved Average per unit rate 4.09 3.99 4.03
True up of Power purchase cost Rs. Crore 4697.18 7369.43 12066.61

The Commission, in light of the above calculations, approves the revised power purchase cost
of UHBVNL at Rs. 15675.12 Crores and that of DHBVNL at Rs. 22480.37 Crores for the FY 2022-
23.

3.12 Revenue from Sale of Power (FY 2022-23)

UHBVNL
It has been submitted by the licensee that actual energy sales of UHBVNL for FY 2022-23 have
increased in comparison to the energy sales approved in the Tariff Order dated 30.03.2022. Post
Covid economic recovery has been robust in UHBVNL area of operation as HT sales were around
20% more than the sales approved by the Hon’ble Commission for FY 2022-23. The consumption
from domestic consumer also witnessed a surge due to new connections and possibly due to
adoption of more electric appliances in the households.
Category wise actual energy sales to the consumers, vis-à-vis approved by the Hon’ble
Commission for FY 2022-23, is tabulated as under: -
Proposed Category wise Energy Sales for FY 2022-23 (In MU)
Sr. Category HERC Approved Actual/Audited Difference
No.
1 Domestic 5573 6676.57 1103.57
2 Non-Domestic 1652
2331.43 -828.57
3 LT Industry 1508
4 HT- Industry 6096
7460.00 1353.00
5 Railways 11
6 AP Sales 3841 4036.91 195.91
7 Streetlight 105 71.85 -33.15
8 Bulk Supply 322 400.78 78.78
9 Lift Irrigation 64
10 MITC 4 677.12 3.12
11 PWW 606
Total 19782 21654.66 1872.66
UHBVNL has orayed that the above actual energy sales may be allowed for Truing up of ARR for
FY 2022-23.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL
DHBVNL has submitted that the actual energy sales for the FY 2022-23 has increased in
comparison to the approved energy sales in Tariff Order dated 30.03.2022.
Category-wise actual energy sold to the consumers vis-à-vis energy sales approved by the
Commission for FY 2022-23 in Tariff Order dated 30.03.2022 is tabulated as under:

Proposed Category wise Energy Sales for FY 2022-23 (MUs)

Consumer Category Approved Audited

Domestic Supply 8,661.30
LT Supply 3,039.79
HT Supply 10,814.78
Agricultural Industry/FPO 26,478.46 17.73
Agriculture 6,129.58
Bulk Supply 1,279.09
Public Water Works/Lift Irrigation/SL 1,066.01
Total 26,478.46 31,008.28

DHBVNL has requested that the above actual energy sales may be allowed for truing up for FY
2022-23.
As per the audited accounts for FY 2022-23, the Discoms have recovered revenue from intrastate
sale of power of Rs. 27565.66 Crore as against Rs. 24684.89 Crore estimated by the Commission.
The True-up of revenue from intrastate sale of power and interstate revenue along with subsidy
for the FY 2022-23 is approved by the Commission, as proposed by the Discoms, based on audited
accounts, as under:
Approved Revenue from sale of power for the FY 2022-23 (Rs. Crore)
Revenue for the FY 2022-23 UHBVNL DHBVNL TOTAL
Revenue from sale of power as per audited accounts including
11,536.80 16,028.86 27565.66
revenue from fixed charges
FSA 3,127.49 4,544.84 7672.33
Total (A) 14664.29 20573.70 35237.99

UHBVNL DHBVNL TOTAL

Revenue from Interstate sale FY 2022-23 (B) 325.27 499.55 824.82

Total 14989.56 21073.25 36062.81

Subsidy Total 2,945.43 3597.18 6542.61
-Subsidy-AP 2,722.54 3,327.54 6050.08
-Subsidy - DS 222.89 269.64 492.53

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

3.13 Revised ARR for the FY 2022-23 after truing-up

In view of the above analysis, the Commission approves the revised ARR for UHBVNL and
DHBVNL as per the details provided in the table(s) below:

Approved True Up of Expenses for FY 2022-23 (Rs. Crore)- UHBVNL

Sr. No Particulars Approved Actual as per Revised (True Up)
Audited Accounts
1 Power Purchase Expense 10,977.94 15,951.58 15675.12
1.1 Power Purchase Expense 9,018.20 13,668.06
1.2 Interstate transmission charges 945.02 1,045.30
1.3 Intrastate transmission & SLDC charges 1,014.72 961.76
Impact of sharing and gains of - 276.46
1.4
distribution losses
2 Operations and Maintenance Expenses 1,630.95 1,693.65 1607.35
2.1 Employee Expense 859.41 857.53 857.53
2.2 Administration & General Expense 112.85 199.15 112.85
2.3 Repair & Maintenance Expense 158.69 93.72 93.72
2.4 Terminal Liability 500 543.25 543.25
3 Depreciation 414.53 374.6 374.60
4 Total Interest & Finance Charges 336.16 410.2 348.13
Interest on Capex Loans 159.61 214.02 130.86
Interest on Working Capital Loans 71.94 109.56 130.65
Interest on Consumer Security Deposits 69.71 61.64 61.64
Other Interest and Finance charges 24.98
34.9 24.98
including Guarantee Fees
5 Return on Equity Capital 250.33 238.31 234.84
6 Other Expenses 9.94 3.63
7 Total Expenditure 13609.91 18678.28 18243.67
8 Less: Non-Tariff Income 221.56 116.27 116.27
9 Net Aggregate Revenue Requirement 13388.35 18562.01 18127.40
10 Total Revenue 14989.56 14989.56
10.1 Revenue from Interstate sales 325.27 325.27
10.2 Revenue from Intrastate sales / Sale of 11,536.80 11536.80
Power
10.3 Revenue from FSA 3,127.49 3127.49
11 Net Surplus / (Gap) -3572.45 -3137.84
12 Subsidy from State Government 2945.43 2945.43
12.1 AP-Subsidy 2,722.54 2722.54
12.2 Domestic Subsidy+ Gaushala 222.89 222.89
12.3 FSA-AP consumers
13 Surplus / (GAP) After Subsidy -627.02 -192.41

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Approved True Up of Expenses for FY 2022-23 (Rs. Crore)- DHBVNL

Sr. No. Particulars Approved(A) Actual (B) Revised
True up
1 Total Power purchase cost 15,110.94 22,760.94 22,480.37
1.1 Power Purchase Expenses 12,509.96 20,007.00
1.2 Interstate transmission charges 1,384.75 1,342.93
1.3 Intrastate transmission charges and SLDC charges 1,216.23 1,130.43
1.4 Sharing of Gain/losses in Power Purchase Cost 280.58 0
2 Operations and Maintenance Expenses 1,855.96 1,974.46 1959.49
2.1 Employee Expense (Net of Capitalization) 1,072.88 984.89 984.89
2.2 Administration & General Expense (Net of 145.77 160.74 145.77
Capitalization)
2.3 Repair & Maintenance Expense 194.43 131.06 131.06
2.4 Terminal Liability 442.88 697.77 697.77
3 Depreciation 446.92 347.75 347.75
4 Total Interest & Finance Charges 427.02 362.62 351.19
Interest on Capex Loans 200.44 135.23 135.23
Interest on Working Capital Loans 104.94 127.26 115.83
Interest on Consumer Security Deposits 86.64 64.33 64.33
Other Interest and Finance charges 11 23.58 23.58
Guarantee Fees 24 12.22 12.22
5 Return on Equity Capital 236.75 211.69 209.36
6 Other Expenses (Debits & Prior period Expenses) 17.67 14.70
7 Total Expenditure 18,077.59 25,675.13 25,362.86
8 Less: Non-Tariff Income 307.66 267.52 267.52
9 Net Aggregate Revenue Requirement 17,769.93 25,407.61 25,095.35
10 Total Revenue - 16,528.41 16,528.41
10.1 Revenue from Interstate sales - 499.55 499.55
10.2 Revenue from Intrastate sales / Sale of Power - 16,028.86 16,028.86
10.3 FSA as per Audited Accounts FY 2022-23 0 0
11 Revenue Surplus/(Gap) -8,879.20 -8,566.93
11.1 Less: Subsidy from Govt. of Haryana for AP - 3,327.54 3,327.54
consumers
Less: Subsidy from Govt. of Haryana for others 269.64 269.64
FSA receivable 4544.84 4544.84
12 Gap After AP Subsidy - -737.18 -424.91
3.14 Revenue Gap of the Discoms for FY 2022-23 (Rs. Crore)
The revenue gap proposed by the Discoms is as under:
Proposed Revenue Gap (Rs. Crore)
Sr. no Particulars Approved UHBVNL DHBVNL Discoms
Aggregate Revenue
1 31,158.29 18,562.04 25,407.62 43,969.66
Requirement
2 Revenue for Discoms 30,735.58 14,807.50 20,125.58 34,933.08
2.1 Sale of Power 24,684.89 11,536.80 16,028.86 27,565.66
2.2 Inter State Sales - 325.27 499.55 824.82

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Sr. no Particulars Approved UHBVNL DHBVNL Discoms

2.3 Subsidy 6,050.69 2,945.43 3,597.17 6,542.60
2.3.1 -Subsidy-AP 6,050.69 2,722.54 3,327.54 6,050.08
2.3.2 -Subsidy-Dom - 222.89 269.64 492.52
3 Revenue Surplus/(Gap) 422.71 -3,754.54 -5,282.03 -9,036.58
4 FSA recovered in FY 2022-23 - - - -
5 Net Revenue Surplus/(Gap) 422.71 -3,754.54 -5,282.03 -9,036.58
Receivable on account of
6 3,127.49 4,544.84 7,672.33
FSA
Revenue Surplus/(Gap) to
7 79.03 -627.06 -737.19 -1,364.25
be carried over

The Commission had quantified RE subsidy of Rs. 6050.69 Crore payable by the State
Government to the Discoms for the FY 2022-23 based on an estimated CoS of Rs. 6.67 (CoS on
LT supply) per unit for A.P. Tube well supply of 9236.43 MU. As the total ARR has now been
revised on account of True-up of the FY 2022-23 and the quantum of power supplied to AP
consumers during the FY 2022-23 has also been revised to 9641.70 MUs. Hence, the subsidy for
the AP Tube well supply payable by the State Government, to keep the tariff at the existing
subsidized levels, also needs to be revised to reflect the corresponding changes in the quantum
and cost of the AP tube-well consumers. As per the audited accounts, total subsidy including AP
subsidy on this account for power supplied by UHBVNL and DHBVNL during the FY 2022-23 is Rs.
2,945.43 crores and Rs. 3597.18 crores respectively. Accordingly, based on the true-up of
expenses for the FY 2022-23 and revised approval of AP sales for the year, the Commission
observes that revised subsidy for AP supply works out to Rs. 7728.98 crores. Based on the true
up of costs, the Discoms have ended the year with a surplus of Rs. 1061.57 crores as determined
below: -
Approved Revenue Gap during True up 2022-23- UHBVNL and DHBVNL

As per Order-
Total ARR for FY 2022-2023 Revised
30.03.2022
UHBVNL Rs. Crore 13,388.34 18127.40
DHBVNL Rs. Crore 17,769.95 25095.35
Total ARR for FY 2022-23 (A) Rs. Crore 31158.29 43222.75
Revenue at current tariff on intrastate sale (B) Rs. Crore 24,684.89 27565.66
Revenue from FSA receivable Rs. Crore 7672.33
Revenue from Interstate sale Rs. Crore 824.82
Total Revenue (C) Rs. Crore 24684.89 36062.81

Total Sales for FY 2022-23 (D) MU 46,260.46 52120.42

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

As per Order-
Total ARR for FY 2022-2023 Revised
30.03.2022
Average Cos for 2022-23 (E= A/D*10) Rs per unit 6.74 8.29
COS at LT level (F) Rs per unit 6.67
Adjusted Cost of Supply for AP consumers (G) Rs per unit 8.21
AP sales for the FY 2022-23 (H) MU 9236.43 9641.70
Revenue from AP sales (I) Rs. Crore 110.00 189.11
Subsidy for AP supply at LT COS (J= (H*G)-I) Rs. Crore 6050.69 7728.98
Subsidy for other consumers (K, as per audited) Rs. Crore 0.00 492.53
Total revenue incl Subsidy (C-J-K) Rs. Crore 30735.58 44284.32
Revenue surplus/(Gap) for FY 2022-23 at current tariff Rs. Crore -422.71 1061.57
Surplus on true up including holding cost 501.74
Distribution loss 14%
Net Revenue Surplus/Gap for the FY 2022-23 Rs. Crore 79.03 1061.57

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 4

Annual Performance Review (APR) for FY 2023-24

4.1 Background
The Discoms have submitted that the Hon’ble Commission has issued the HERC (Terms and
conditions for Determination of Tariff for Generation, Transmission, Wheeling and Distribution
& Retail Supply under Multi Year Tariff framework) Regulations, 2012 on 5th December 2012 for
Control Period of FY 2014-15 to FY 2016-17. Further, the Hon’ble Commission (with subsequent
amendments) has extended the Control Period of MYT Regulation, 2012 till FY 2019-20.
Further, the Hon’ble Commission, on 31st October 2019, notified HERC (Terms and conditions for
Determination of Tariff for Generation, Transmission, Wheeling and Distribution & Retail Supply
under Multi Year Tariff Framework) Regulations, 2019 for Second Control Period from FY 2020-
21 to FY 2024-25. As per Regulation 11.6 “Mid- Year Performance Review and Tariff Setting” of
MYT Regulation 2019, Annual Performance Review (APR) is to be done in accordance with the
Tariff Order of the relevant year. The relevant extract of the Regulation is provided as follows: -
“11. Mid -Year Performance Review and Tariff Setting
11.6 “The Commission shall review/consider, during the control period, the application made
under this Regulation as also the application for truing up of the ARR of the previous year, as per
provision of the Regulation 13, on the same principles as approved in the MYT order on the
original application for determination of ARR and tariff. The review / true–up for FY 2018-19 and
FY 2019-20 shall, however, be done on the same principles as approved in the tariff order for FY
2018-19 and for FY 2019-20…”
Tariff Order on ARR and Retail Supply & Distribution Tariff for FY 2023-24 was issued by the
Hon’ble Commission on 15.02.2023.
In line with the above, the Discoms have submitted Annual Performance Review of ARR for the
FY 2023-24. The Petitioner(s) have considered actual available data for the first half of current
financial year, pro-rata projections, and escalations as per principles defined in the MYT
Regulations, 2019 to project the revised ARR for FY 2023-24. Projected ARR for APR Year vis-a-
vis approved expenses is submitted for the approval of Hon’ble Commission.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

4.2 Energy Sales

UHBVNL
Revised estimates for energy sales have been considered on lower side than the approved energy
sales for the relevant year. Total energy sales of 22,653.81 MUs is re-estimated against 25,263
MU allowed in the tariff order dated 15.02.2023. In this regard, it is pertinent to note that that
the sales were approved on the higher side (in the tariff order dated 15.02.2023) than what was
petitioned by UHBVNL during submission of ARR last year. The category-wise revised sales
estimates are provided herewith in this section.
Hon’ble Commission has created new consumer categories by merging the previous categories.
Being non-availability of historical data of such consumer category, revised sales estimates have
been considered after merging the categories as per tariff order dated 15.02.2023.
Revised sales estimates have been calculated based on the actual data of first half and projected
figures for second half based on 2-to-7-year CAGR on the actual data of corresponding period.
Hence, the category-wise sales for H2 of FY 2022-23 have been increased by selected CAGRs of
past years to project the sales for H2 of FY 2023-24. The projected H2 sales of FY 2023-24 thus
have been added to actual H1 sales of FY 2023-24 to arrive at the revised sales for the whole
year.
For domestic category, consumption is normalized using long term trend and the sales for second
half is adjusted with 7-year CAGR with 9.79% growth rate.
Sales for Non-Domestic category have been included with LT Supply and projected cumulatively.
7-year CAGR of 11.34% has been considered for estimating the H2 sales for HT Supply category
given that there is an increase of 14% in HT sales from H1 of FY 2022-23 to H1 of FY 2023-24.
For LT supply category, moderate growth of 10.00% has been considered.
While calculating AP sales for H2 of FY 2023-24 as per HERC methodology, moderate growth of
2.64% on AP feeder input energy is considered which is derived from the growth in AP connected
load from FY 2021-22 to FY 2022-23.
For Bulk Supply category, sales for second half are projected keeping in mind long term trend
and thus 5-year CAGR of 5.67% has been considered to estimate H2 sales.
Sales for Street Lighting for H2 have been estimated considering 7-year CAGR of 7.70%.
MITC and Lift Irrigation sales have been merged with PWW category and the cumulative sales is
projected based on 7-year CAGR of 4.76%.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Revised estimates of category wise energy sales vis-à-vis approved for UHBVNL for FY 2023-24
are tabulated as follows: -

UHBVNL proposed Category wise Energy Sales for FY 2023-24 (in MUs)
Sales Projection for FY 2023-24
Category Actual FY 2022-23 Selected Proj.
Approved Total
(H1) (H2) CAGR (H2)
Domestic 7656.00 3992.24 2789.87 9.79% 3,062.97 7,055.20
HT Supply/Railway
8014.00 3975.11 3892.30 11.34% 4,333.81 8,308.92
Traction
LT Supply/NDS 4423.00 1292.13 1125.15 10.00% 1,237.66 2,529.79
Agriculture 3669.00 2123.69 1464.41 2.64% 1503.10 3,626.80
Bulk Supply 347.00 193.98 176.35 5.67% 186.35 380.33
Street Lighting 73.00 30.82 40.76 7.70% 43.89 74.72
PWW/Lift
781.00 326.89 335.20 4.76% 351.16 678.05
Irrigation/MITC
Total 25263.00 11934.86 9824.04 10,718.95 22,653.81
UHBVNL requested that the Commission may approve the category wise energy sales as
projected in the above table.
DHBVNL
Hon'ble Commission vide its Tariff Order dated 15.02.2023 has approved Energy Sales of 31,283
MUs for DHBVNL.
DHBVNL has estimated the revised sales for FY 2023-24, based on of actual sales for the first half
and projected sales of the second half.
The Hon'ble Commission in Tariff Order for FY 2021-22 has merged NDS category (upto 50 kW)
& LT Industry (upto 50 kW) into LT supply. Further, NDS category (above 50 kW), LT Industry
(above 50 kW), HT Industry & Metro Supply are merged into HT supply. Since, the historical data
is not available in the newly formed categorization, hence, the projections have been made
based on the previous year categorization.
The sales projection for the second half of FY 2023-24 have been worked out based on 2 to 7
years CAGR and actual sales of corresponding period in the past years keeping FY 2022-23 as
base year. 2 to 7 years CAGR of Actual sales in H2 of FY is shown in table below:
DHBVNL CAGR of Actual sales in H2 of FY (in %)
CAGR for H2
Category
2 years 3 years 5 years 7 years
Domestic 11.31% 10.59% 10.42% 8.70%
LT Supply 13.50% 5.56% 5.39% 5.33%
HT Supply 12.79% 12.17% 6.05% 8.41%
Agriculture -0.80% 4.37% 2.72% 4.49%

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Bulk Supply 8.57% 5.73% 10.57% 11.58%

Lift Irrigation/ PWW/ Street Lightning 4.48% 2.19% 3.40% 5.83%

Category wise energy sales approved vis-a-vis revised projection of DHBVNL for FY 2023-24 is
tabulated as under: -
DHBVNL proposed Energy Sales projection for FY 2023-24 (MUs)

H2 FY 2023-24
FY Actual Proj. Revised
Category 2022-23 Approved CAGR
(H1) (H2) Estimate
(1) (2) (3) (4) (5)=(1)*(1+(4)) (6) = (3+5)
Domestic 3758.09 9454.00 4842.18 11.31% 4183.02 9025.20
LT Supply 2334.04 5155.00 2995.31 5.56% 2463.90 5459.20
HT Supply 4284.45 9041.00 4634.42 8.41% 4644.84 9279.26
Agriculture 3434.54 5215.00 2935.71 4.49% 3588.84 6524.55
Bulk Supply 548.88 1299.00 768.20 11.58% 612.45 1380.65
Lift Irrigation/
PWW/ Street 538.20 1119.00 533.28 5.83% 569.58 1102.87
Lightning
Total 14898.21 31283.00 16709.11 16062.63 32771.74

DHBVNL requested the Commission to approve the category wise energy sales for FY 2023-24 as
projected above.

4.3 Transmission Losses

The Hon'ble Commission in tariff order dated 15.02.2023 has approved power purchase cost for
FY 2023-24 considering the interstate transmission losses as 3.48% subjected to truing up of the
same in relevant year. However, based on the transmission loss details published on Power
System Operation Corporation Ltd. (POSOCO) website, the interstate losses are being
determined on national basis and based on of last 52 weeks data, the average loss level works
out to 3.62%. (Reference link of website: https:// posoco.in/ side -menu - pages/ applicable –
transmission - losses / transmission - losses - 2023-24 /) Thus, Discoms have requested that the
same may be considered for projecting power purchase cost for the APR year.
Intrastate transmission losses for APR year are considered at 2.05%, same as approved by the
Hon'ble Commission in the Tariff Order dated 15.02.2023.

4.4 Distribution Losses

The Hon’ble Commission vide its Tariff Order dated 15.02.2023 had approved the distribution
loss of 12.00%. The same is being considered by Discoms for the purpose of the APR projections.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

4.5 Collection Efficiency

Collection efficiency of 99.5% as specified by the Hon’ble Commission in MYT Regulation 2019,
has been considered for APR projections. Accordingly, the AT&C loss for APR year is tabulated as
follows:-
Distribution Loss Trajectory for APR year FY 2023-24
Particulars FY 2023-24
Distribution Losses 12.00%
Collection Efficiency 99.50%
AT&C Losses 12.44%

4.6 Transmission Charges

UHBVNL
For the purpose of APR estimations, the Inter-State and Intra-State transmission charges have
been estimated considering the actual charges of first half (H1) of 2023 to be equal for the second
half i.e., October 2023 to March 2024. UHBVNL has requested to approve the estimated ISTS and
InSTS Charges for FY 2023-24 as under:

Proposed by UHBVNL: Transmission Cost (Rs. Crore) for FY 2023-24

FY 2023-24
Particulars
H1 H2 Total
Inter-State Transmission Cost 454.10 454.10 908.21
Intra-State Transmission Cost 457.74 457.74 915.49
Total Transmission Cost 911.84 911.84 1823.70

DHBVNL
For APR projections of FY 2023-24 Inter-state and Intra-state transmission charges are
considered by DHBVNL based on the charges paid in H1 of FY 2023-24:
Proposed by DHBVNL: Transmission Charges for FY 2023-24 (Rs. Crore)
Particulars FY 2023-24
Inter State Transmission Charges 1,324.86
Intra State Transmission Charges 1,324.38

4.7 Power Purchase Cost

UHBVNL
The power purchase cost of UHBVNL including interstate and intrastate transmission charges
works out to Rs. 14,807.95 Crore for FY 2023-24. The details of the same has been tabulated as
under: -

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

UHBVNL proposed Power Purchase Cost Summary for FY 2023-24 (Rs Crs)
Particulars Units FY 2023-24
Power Purchase Cost Rs. Crore 12984.26
Inter-State Transmission Rs. Crore 908.21
Intra-state Transmission Rs. Crore 915.49
Total Power Purchase cost Rs. Crore 14807.95
PP Quantum MU 28,708.41
Average power purchase cost Rs/kWh 5.16
DHBVNL
The power purchase cost of DHBVNL including interstate and intrastate transmission charges has
been tabulated as under: -
DHBVNL Proposed Power Purchase Cost Summary for FY 2023-24
FY 2023-24
Particulars
(Approved) (Projected)
Power Purchase Cost (Rs. Crore) 16,351.48 18,772.43
Power Purchase Quantum (MUs) 36,292.87 41,530.53
Average Power Purchase Cost (Rs/kWh) 3.83 4.52
Inter-state Transmission Cost (Rs. Crore) 1,388.96 1,324.86
Intra-state Transmission Cost & SLDC cost (Rs. Crore) 1,220.41 1,324.38
Total Power Purchase Cost (Rs. Crore) 18,960.86 21,421.67
Average Power Purchase Cost including Transmission cost (Rs/kWh) 5.22 5.16
DHBVNL has prayed that the Commission may approve the above power purchase cost for FY
2023-24 as submitted in above table.

4.8 Energy Balance

Energy available from long term tied up generating sources and energy requirement at state
periphery grossed up with above mentioned transmission & distribution losses are considered
for estimating the energy balance for APR year.
UHBVNL
The detailed calculation for UHBVNL is tabulated as follows:-

Energy Availability for FY 2023-24

Energy Balance-UHBVNL Units FY 2023-24
Energy Requirement
Energy Sales MU 22654
T&D loss %age 12.00%
Energy Input required at DISCOM Periphery MU 25743
Intra- State Transmission Loss %age 2.05%
Energy Requirement at State Periphery MU 26282

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Energy Balance-UHBVNL Units FY 2023-24

Energy Purchase
Total Energy Available (Ex-Bus) MU 28708
Inter-State Power Purchase considering MOD MU 24546
Inter-State Transmission Losses MU 3.62%
Inter-State Power Purchase at State Periphery MU 23656
Intra-State Power Purchase considering MOD MU 4163
Power Purchase at State Periphery MU 27819
Surplus MU 1537

The surplus energy is either banked or traded-off in exchange at average variable power
purchase cost to minimize the trading loss of the DISCOM. The indicative surplus position as
tabulated above is only in terms of energy, whereas in real time scenario depending on demand-
supply position in terms of MW, short term energy (either from collective or bilateral mode) is
procured to fulfil the energy requirement of the DISCOM. The status of surplus power will be
submitted before the Commission at the time of truing-up of ARR for FY 2023-24.
UHBVNL requested the Commission that the revised energy balance for FY 2023-24 may be
approved.
DHBVNL
The detailed calculation for DHBVNL is tabulated as follows:
Energy Balance for FY 2023-24
FY 2023-24
Energy Balance Units
(Approved) (Projected)
Energy Sales MUs 31,283.00 32,771.74
T&D loss % 12.00% 12.00%
Energy Input at Discom Periphery MUs 35,548.86 37,240.61
Intra- State Transmission Loss %age 2.05% 2.05%
Energy Input at State Periphery MUs 36,292.87 38,020.03

Total Energy Available (Ex Bus) MUs 41,530.53

Inter-state Power Purchase considering MoD MUs 35,508.47
Inter State transmission losses % 3.62%
Inter-state Power Purchase at State Periphery MUs 34,221.35
Intra state Power Purchase Considering MoD MUs 6,022.06
Power Purchase at State Periphery MUs 40,243.42
Surplus Mus 2,223.39

The surplus energy is either be banked or traded-off in exchange at average variable power
purchase cost to minimize the trading loss of the Discoms. The indicative surplus position as
tabulated above is only in terms of energy whereas in real time scenario depending on demand-

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supply position in terms of MW, short term energy is either from collective or bilateral mode is
to procure the energy requirement of the Discoms. The status of surplus power will be submitted
at the time of truing-up of ARR for FY 2023-24.
The Commission is requested by Discoms to approve the revised energy balance for FY 2023-24.

4.9 Capital Expenditure

UHBVNL
Capital Expenditure Plan of Rs. 1000 Crore for UHBVNL is approved by the Commission in the
Tariff Order dated 15.02.2023. The same has been considered by the Petitioner to determine the
revised estimates for APR year.
Capital Expenditure is funded by debt/loan, consumer contribution and equity support provided
by the State Govt. The table below shows the funding structure of the proposed Capital
Expenditure plan for APR year.

UHBVNL proposed Funding of capital expenditure of 2023-24 (Rs Crore)

Particulars Amount (in Cr.)
Consumer Contribution 37.50
Equity 192.50
Debt 770.00
Total 1000.00
DHBVNL
Capital Expenditure Plan is funded from debt availed from financial institutions like REC, PFC and
others, consumer contribution and equity support provided by the State Govt. Table below
shows the funding structure of the proposed Capital Expenditure plan for APR year for DHBVNL.
DHBVNL proposed Funding of Capital Expenditure of FY 2023-24
Amount
Particulars %
(Rs. Crore)
Consumer Contribution & Grant 11.31% 135.76
Equity 17.74% 212.85
Debt 70.95% 851.39
Total 100% 1200.00
4.10 Computation of Inflationary Indices
Based on the CPI and WPI indices of current and previous year, Inflation factor for APR year is
calculated as per the methodology specified in HERC MYT Regulations, 2019. Detailed calculation
for Inflation factor is tabulated as follows:
Inflation Factor for APR year
Particulars WPI CPI Total
Weightage 0.45 0.55 1

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Particulars WPI CPI Total

Avg Indexation for FY 2022-23 152.5 377.6
Avg Indexation n (Index * Wt.) 68.6 207.7 276.3
Avg Indexation for FY 2021-22 139.4 356.1
Avg Indexation n-1 (Index * Wt.) 62.7 195.8 258.6
Combined Inflation (Indxn/Indxn-1) 6.87%
4.11 Revenue Estimation
UHBVNL
Based on projected sales and applicable retail supply tariff, the revenue from sale of power of
various categories of UHBVNL is tabulated as follows:

UHBVNL proposed Revenue Estimations for FY 2023-24 (Rs Crore)

Category Revised Estimates
Domestic 3,489.31
HT Supply 6,307.02
LT Supply 1,872.73
Agriculture 53.29
PWW/Lift Irrigation/MITC/Street Light 612.64
Bulk supply 273.74
Total Revenue 12,608.83
Collection Efficiency 99.50%
Revenue Realised 12,545.78
DHBVNL
Revenue from sale of power is determined on basis of the projected sales and current level of
retail supply tariff as approved by the Hon’ble Commission in Tariff Order dated 15.02.2023.
Category-wise revenue estimated from sale of power by DHBVNL for FY 2023-24 is given below:
DHBVNL proposed Revenue Estimations for FY 2023-24 (Rs. Crore).
Sr.no. Category Projected Amount
1 Domestic 4,401.30
2 LT Supply 2,385.20
3 HT Supply 9824.99
4 Agro Industry/FPO 8.89
5 Agriculture 64.62
6 Bulk Supply 1043.38
7 PWW/ Street light/Lift Irrigation 919.87
8 Total Revenue 18,648.25

4.12 Aggregate Revenue Requirement for FY 2023-24

The revised estimate of Aggregate Revenue Requirement for APR year is tabulated as follows: -

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UHBVNL proposed Aggregate Revenue Requirement for FY 2023-24 (Rs. Crore)

Sr. No Particulars Approved Revised Estimates
1 Total Power Purchase Expense 13,990.30 14,807.95
1.1 Power Purchase Expense 11,931.85 12,984.26
1.2 Interstate transmission Charge 1,013.54 908.21
1.3 Intrastate transmission charges and SLDC charges 1,044.91 915.49
2 Operations and Maintenance Expenses 1,816.64 1,811.28
2.1 Employee Expense 1,018.99 967.14
2.2 Administration & General Expense 162.58 214.33
2.3 Repair & Maintenance Expense 185.07 179.81
2.4 Terminal Liability 450.00 450.00
3 Depreciation 462.66 425.69
4 Total Interest & Finance Charges 323.36 470.58
4.1 Interest on CAPEX loans 105.48 172.82
4.2 Interest on WC loans including CC/OD limits 116.39 150.28
4.3 Interest Cost on Consumer Security Deposit 66.59 112.58
4.4 Other Interest & Finance Charges 34.90 34.90
5 Return on Equity Capital 277.67 305.20
7 Total Expenditure 16,870.63 17,820.70
8 Less: Non-Tariff Income 278.43 278.43
9 Net Aggregate Revenue Requirement 16,592.20 17,542.27
DHBVNL proposed Aggregate Revenue Requirement for FY 2023-24 (Rs. Crore).
APR
S.No. Particulars FY 2023-24
Approved Projected
1.0 Power Purchase Expenses 18,960.86 21,421.67
1.1 Power Purchase Cost 16,351.48 18,772.43
1.2 Transmission Charges 1,388.96 1,324.86
1.3 Transmission Charges & SLDC 1,220.41 1,324.38
2.0 Operation & Maintenance Expenses 2,200.99 2,276.49
2.1 Employee Expenses (net) 1,271.32 1,175.85
2.2 Administration & General Expenses (net)* 144.34 171.78
2.3 Repair & Maintenance Expenses 235.33 231.10
2.4 Terminal Benefits 550.00 697.77
3.0 Depreciation 452.20 510.32
4.0 Interest & Finance Charges 473.99 605.20
4.1 Interest on Long Term Loan 154.59 165.51
4.2 Interest on Working Capital 186.95 179.81
4.4 Interest on Consumer Security Deposit 100.06 185.45
4.5 Other Interest & Finance Charges 8.40 24.17
4.9 Guarantee Fee 24.00 50.26
5 Return on Equity Capital 285.13 271.72
6 Prior period expenses & other expenses 0 0
7 Other Debts, (including wealth tax) 0 0
8 Provisions for bad and doubtful debt 0 93.24
9 Aggregate Revenue Requirement 22,373.16 25,178.64
10 Less: Non-Tariff Income 279.22 308.61
11 Net Aggregate Revenue Requirement 22,093.94 24,870.03

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

4.13 Revenue Gap

Based on the revised estimates for Aggregate Revenue Requirement, Haryana Discoms have
proposed the details of revenue gap for the APR year tabulated as follows:
UHBVNL and DHBVNL proposed Revenue Gap for FY 2023-24 (Rs Crore)
Sr. Revised Estimates
Particulars Approved
no UHBVNL DHBVNL Haryana
1 Aggregate Revenue Requirement 38,686.15 17,542.27 24,870.03 42,412.30
2 Less: Revenue for Discoms 36,714.05 15,780.75 23,528.37 40,069.74
2.1 Revenue from Sale of Power 30,944.11 12,545.78 18,648.25 31,194.03
2.2 Revenue from Inter-state Sales 350.00 889.36 1,239.36
2.3 Subsidy from GoH 5,769.94 2,884.97 2,884.97 5,769.94
3 Less: FSA - 760.62 1,105.79 1,866.41
4 Revenue Surplus/(Gap) - 1,972.10 -1,000.89 -1,341.66 -2,342.56
5 Revenue surplus for FY 2021-22 1432.30 1844.87
6 Holding Cost @ 8.5% for 1.5 Year 182.62 235.22
7 Net Revenue Surplus/(Gap) -357.18 -262.47
The above revenue gap is proposed to be met from efficiency improvement in subsequent year
and Discoms requested that aforesaid revenue gap for APR year may be allowed and adjusted
appropriately in the relevant year.
The Commission has considered the prayer of the Discoms for revision of ARR for the FY 2023-
24 as a consequence of the revised APR estimates provided by them and observes that the
expenditure incurred during the APR period as well as the consumer category wise sales and
revenue are on a projected basis and not final and also not based on the audited accounts.
Hence, the same, at this stage, do not call for any revision by substituting one estimated figure
by another.
Accordingly, in view of the regulations occupying the field, the Commission is of the considered
view, as also observed in the past, that it would not be appropriate to replace one set of
estimated figures with another set of estimates for a small amount. Further, in view of the fact
that the year is now almost over and it would be appropriate to examine the financial impact
of mid-term performance review for the FY 2023-24 only once the Audited Accounts for the
year are available. Hence, at this point of time the Commission is not inclined to revise the ARR
for the FY 2023-24 as prayed for by the petitioner(s).

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 5

Aggregate Revenue Requirement (FY 2024-25)

5.1 Brief Introduction

The petitioner(s) i.e. UHBVNL and DHBVNL have submitted the Aggregate Revenue Requirement
(ARR) for the fourth year of the MYT Control Period i.e. FY 2023-24 on 30.11.2022. It has been
averred that the Hon’ble Commission has subsequently issued ARR / Tariff Order on 15.02.2023.

That in line with the approach adopted by the Hon’ble Commission, in the previous tariff order,
for approving various components of the ARR and provisions specified in the MYT Regulations,
the instant petition for ARR of the FY 2024-25 has been filed for consideration and approval of
the Commission.

That regulation 71 & 75 of the HERC MYT Regulation, 2019, provides that a petition for
determination of Tariff for the terminal year of MYT Control Period, i.e. FY 2024-25, has to be
filed in the Commission on or before 30th November of the year preceding the ensuing year i.e.
30.11.2023. Further, the petition for seeking approval of the Aggregate Revenue Requirement,
for the ensuing years, is required to be prepared in accordance with the details provided under
the regulations 8.3, 11 & 13 of MYT Tariff Regulation, 2019. The relevant portion of aforesaid
regulations cited by the petitioner(s) is reproduced below:-

“71. Tariff Filings

…………..
71.2 Tariff filing for the control period under MYT framework
71.2.1 The generating company and the licensees shall file an application for approval of ARR
for their respective businesses for each year of the control period and tariff for the first
year of the control period consistent with the business plan and the capital investment
plan approved by the Commission. The ARR and tariff filing shall be filed by 30th
November of the year preceding the 1st year of the control period along with requisite
fee in accordance with the provisions of Haryana Electricity Regulatory Commission
(Fee) Regulations amended from time to time. The application shall contain all the
components of the ARR and tariff as provided in these Regulations….
71.5 Filing for Mid-year performance review, True-up and determination of tariff for
ensuing year
The generating company and the licensees shall file their application for mid-year
performance review of the current year, true-up of the previous year and tariff for the
ensuing year along with requisite fee by 30th November of each year of the control
period as per the details mentioned in the Regulation 11 & 13 for the Commission’s

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review, true-up of uncontrollable/controllable items in accordance with Regulation 8.3

and approval of tariff for the ensuing year.
The MYT filing shall also contain an application for mid-year performance review
of and true-up petition.”
The Discoms have submitted that Aggregate Revenue Requirement (ARR) for FY 2024-25 has
been prepared as per the approach specified under the Regulations 8.3 of HERC MYT Regulations,
2019 and its subsequent amendment. The financial components of the Aggregate Revenue
Requirement for FY 2024-25 have been projected based on the past trend, regulatory norms,
activities planned and undertaken for the ensuing year. The relevant extract of the aforesaid
regulation is reproduced as under:

“8.3.4 The Aggregate Revenue Requirement of the Retail Supply Business to be recovered
through retail supply tariff of the distribution licensee(s) shall comprise the following: -
i) Power Purchase Cost
ii) Transmission Charges (Inter State & Intra State)
iii) Interest (Term Loan and normative Working Capital Loan, Consumer Security
Deposit)
iv) Depreciation
v) Operation & Maintenance Expenses
vi) Provision for bad and doubtful debt subject to a ceiling of 0.5% of the account
receivable as per the latest available audited accounts.
vi) Return on Equity Capital
Provided that the ARR computed as per above shall be net of Non-Tariff Income, income
from Other Business, receipts from cross – subsidy surcharge and additional surcharge
etc.
Provided further that the prior period expenses shall be considered at the time of truing
– up on a case to case basis subject to prudence check. However, all penalties payable
by the distribution licensee arising from Commission’s order, courts / tribunal, CGRF /
Ombudsman shall not be allowed to be recovered through ARR.”
Accordingly, the details of projections of the financial parameters of the Aggregate Revenue
Requirement for the FY 2024-25, filed by the Discoms, have been taken on record. The
Commission’s analysis and order on each of the sale projections and expenditure items are given
in the paragraphs that follows.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

5.2 Assessment of Agriculture Tube well (AP) Sales: FY 2022-23 (True up), FY 2023-24 (revised)
& FY 2024-25 (projected)

The Commission has examined the submissions of the DISCOMS (UHBVNL and DHBVNL) for the
AP sales for the period mentioned above. It needs to be noted, from past experience, that
projections based on actual segregated feeder level data is more scientific with significantly
higher degree of accuracy. The only aberration is the actual losses between the 11 kV AP
segregated feeder and point of consumption. This minor error in forecasting creep in because of
unmetered AP supply and dead /defective/un-read meters where AP connection, historically, has
been released through meters.

5.2.1 True up of AP Sales (FY 2022-23)

The petitioners, based on actual AP sales, have prayed for approval of Rs. 6050.08 Crores as
revised RE Subsidy for FY 2022-23. The Commission in the Tariff order dated 30/03/2022 had
approved Rs. 6050.068 Crores as RE Subsidy for the FY 2022-23 based on projected sales as well
as LT COS estimated by the Commission for FY 2022-23.

The AP consumption of the two Distribution Licensees , based on above data submitted by the
petitioners for FY 2022-23, is worked out as under:-

AP Tube well Consumption UHBVNL DHBVNL

(2022-23) (2022-23)
AP sales recorded on 11 kV segregated AP feeders (MUs) 4802.75 6418.35
Loss @ 16% 768.44 1026.94
AP feeders net sales (MUs) 4034.31 5391.42
Consumption of AP on other feeders (MUs) 18.05 304.74
(Less) Consumption of other category consumers on
segregated AP feeders (MUs) 15.45 91.37
Total AP consumption 4036.91 5604.79
Total AP consumption of two DISCOMs (rounded off) 9641.70
Total AP Sales of DISCOMs for FY 2022-23 approved by
9236.77
Commission in Tariff Order dated 30/03/2022. (MUs)

It is evident from the above table that the actual AP consumption i.e. 9641.70 MU for the FY
2022-23 is higher than the AP consumption approved by the Commission in its Tariff Order dated
30/03/2022. Accordingly, the total AP sales, in respect of both the DISCOMs, is trued up as
9641.70 MU for FY 2022-23 (UHBVNL- 4036.91MU and DHBVNL-5604.79MU).

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The Commission, vide Tariff Order dated 15/02/2023, had directed that the Managing Director
of DHBVNL to check the AP sales figures and input energy and submit a report on the running
of the AP tube wells on non-AP feeders within one month of issue of the said order besides
reconciliation of figures.
In response to above, DHBVNL Vide memo no. Ch-113/SE/RA-761 dated 23/08/2023 has
submitted as under:-
‘It is submitted that, M/s Parnat Engineers Pvt. Ltd. firm had calculated the T&D losses (based on
empirical formulae) as 15.15%, 15.56% and 16.10 % for the FY 2017-18, 2018-19 and 2019-20
respectively. However, the losses of DHBVNL on AP feeders’ range between 8% to 9% during the
same period.
Further, following issues have been submitted:
1. Out of the total AP connections (as on 31.03.2022), 26% of AP connections are unmetered.
2. Defective meter on AP connections as on 31.03.2022 is 93393, which is 28% of Total AP
connections. Billings of these connections are done on provisional basis as per Sales Circular:
D-28/2013 (as per Hon’ble HERC directions issued vide memo no. 7011/HERC/T126 dated
13.12.2012 and order issued in case no. HERC/RA-01 of 2013 dated 06.06.2013).
3. During end of FY 2020-21, 10 sub- division were under migration to R-APDRP system, which
were not billed during this period. Further, with completion of migration process, same were
billed in FY 2021-22. The process of migration of all sub- divisions has been completed in
March 2023 consequently, during this period, the billed energy on AP feeders exceeds the
input energy.’
The reasons of AP consumption on Non-AP feeder as provided by the petitioner(s) are as given
below: -
a) 14175 no. of AP consumer with connected load of 107.1 MW were not shifted from Non-AP
feeder due to non-availability of right of way.
b) 2528 no. of AP consumer with connected load of 14.27 MW were temporarily shifted to
Non-AP feeders due to break down.
The Commission observes that the DHBVNL Agriculture sales for FY 2022-23 as per audited
account is 6129.58 MUs. In line with methodology adopted by the Commission, AP sale is
5604.79, whereas in the case of UHBVNL Agriculture sales for the FY 2022-23, as per audited
account, is 4036.91 MU and in line with methodology of the HERC is also 4036.91 MU. In case of

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL, there is a significant difference i.e. of 524.79MUs in sales for FY 2022-23. Similar
differences were also observed in the previous fiscal year and accordingly, DHBVNL was directed
to submit the reasons for contradictory stand on the aberrations pointed out in the AP sales
along with relevant authenticated data/study in support of reply but no satisfactory reply has
been submitted by the licensee. The reason for difference between both figures needs to be
explained with authentic data and submission that as large as 14175 AP connections were not
shifted due to right of the way besides connection of 10 subdivision were not billed due to
migration from non-RAPDRP to RADRP does not hold good as segregation of feeders was
reported to be completed a long back by the Nigam whereas migration from non APDRP to
RAPDRP may have taken place in a period of two months. Moreover, billing of AP connections
for the unmetered AP Tube well consumers are done on a flat rate basis and even for majority
of metered consumers due to non-taking reading, billing is being done on flat rate and as such
migration does not affect billing.

In view of the above discrepancies in the AP sales figures, the Commission directs that DHBVNL
will ensure 100% shifting of AP connections on segregated feeders instead of lame excuses
time and again.

5.2.2 AP Sales Estimation for FY 2023-24 and for FY 2024-25

a) AP Sales Estimation for FY 2023-24:

UHBVNL has submitted that while calculating AP sales for H2 of FY 2023-24 as per the HERC
methodology, a moderate growth of 2.64% on AP feeder input energy has been considered
on the basis of the growth in AP connected load from the FY 2021-22 to FY 2022-23
DHBVNL has submitted that a nominal rate of 4.49% increase has been considered to project
the sale of 2nd half (H2) of 2023-24.
The AP Sales Projection by DISCOMs for FY 2023-24 is as under:
Sr. No. AP sales FY 2023-24
1 UHBVNL (MUs) 3626.80
2 DHBVNL (MUs) 6524.55
3 Total AP Sales of DISCOMs (1+2) 10151.35
The Commission, in its Tariff Order dated 15/02/2023, for maintaining uniformity in the
projection methodology for both the DISCOMs, had projected AP Consumption for the FY
2022-23, considering the actual consumption in the first half of the FY 2022-23 and projected

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

second half on the basis of AP consumption of previous year’s second half.

The Commission considered the actual month-wise AP sales provided by the DISCOMs and
analysed the AP Sales on the basis of actual sales of FY 2017-18 to FY 2022-23 and based on
CAGR observed for 2/3/5 years, observes that for UHBVNL, AP sales considering 5-year CAGR
for second half (H2) works out 0.57% whereas 5-year CAGR for DHBVNL for the second half
is 0.29%. The relevant calculations are tabulated as under:
Table: AP Sales Projection FY 2023-24 of UHBVNL (MU)
AP Sales H2 (Oct-March) CAGR (2017-18 to 2022-23) FY 2023-24
Projections FY FY FY FY FY FY 5 3 2 H1 H2 (H1+H2)
2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 (Actual) (Proj)
Segregated 1,690.99 1,385.81 1797.01 2042.24 1,236.43 1,739.57 0.57% -1.08% -7.71% 2529.33 1756.97 4286.30
AP feeders
Normative 1,420.43 1,164.08 1,509.49 1,715.48 1,038.60 1,461.24 2124.64 1475.85 3600.49
consumption
@16% of loss
Billing on 24.79 20.61 22.83 30.39 9.89 5.71 9.01 5.77 14.78
other than AP
feeder
Other 17.37 9.75 6.56 7.09 7.97 7.37 CAGR =1% 9.95 7.44 17.39
category
consumption
on AP Feeders
Net 1,427.85 1,174.94 1,525.76 1,738.78 1,040.52 1,459.58 2123.70 1474.17 3597.87
Normative AP
Consumption

Table: AP Sales Projection FY 2023-24 of DHBVNL (MU)

AP Sales H2 (Oct-March) CAGR (2017-18 to 2022- FY 2023-24
Projections 23)
FY FY FY FY FY FY 5 3 2 H1 H2 (H1+H2)
2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 (Actual) (Proj)
Segregated AP 3,082.35 2,797.36 2491.11 2989.80 2,375.28 3,127.14 0.29% 7.87% 2.27% 3,038.62 3158.41 6197.03
feeders
Normative 2,589.17 2,349.78 2,092.53 2,511.43 1,995.24 2,626.80 2,552.44 2653.07 5205.51
consumption
@16% of loss
Billing on other 71 110.33 121.80 124.43 301.222 318.8 225.34 321.99 547.33
than AP feeder
CAGR =1%
Other category 30.14 33.57 32.71 30.65 3.023 57.2 60.05 57.77 117.82
consumption on
AP Feeders
Net Normative 2,630.03 2,426.54 2,181.62 2,605.21 2,293.44 2,888.40 2,717.73 2917.28 5635.01
AP Consumption

The Commission has considered CAGR of 1% to project the 2nd half AP sales for the FY 2023-24.
The AP sales for FY 2023-24 is calculated by taking actual sales of H1 of FY 2023-24 and including
projected sales of H2 by considering CAGR of 1%. The AP sale for UHBVNL and DHBVNL for FY
2023-24 worked out as evolved as under:
Sr. No. AP sales FY 2023-24
1 UHBVNL (MUs) 3597.87
2 DHBVNL(MUs) 5635.01
3 Total AP Sales of DISCOMs (1+2) 9232.88
b. AP Sales Estimation for FY 2024-25:

The DISCOMs have submitted that the Haryana Government has promoted various schemes for

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crop diversification due to which some growth in agriculture tube-well consumption is recorded
despite mandatory use of energy efficient pumps sets for release of new connections as well as
water conserving micro / drip irrigation system. UHBVNL has projected AP sales by considering a
nominal growth rate of 2.64% and DHBVNL has considered 2.4% growth rate.
The Commission observes that 2.64% and 2.4% growth rate considered by the UHBVNL and
DHBVNL respectively is without any firm and convincing basis particularly when energy efficient
pumps are installed and diversification of crops has been taken place. Therefore, the Commission
has analysed 2 to 5- year CAGR for the period from FY 2017-18 to FY 2022-23 on considering
actual sales of these years.
The Commission observes that 5 years CAGR is 0.48% and 0.26% for UHBVNL and DHBVNL
respectively, therefore, the CAGR @ 1% for projecting AP Sales for FY 2024-25 is based on the AP
sale projection as above explained. The relevant calculation is tabulated as under:
UHBVNL
Table: AP Sales Projection FY 2024-25 of UHBVNL (MU)
Consumption FY 2017- FY 2018- FY 2019- FY 2020- FY 2021- FY 2022- FY 2023- CAGR (2017-18 to 2022-23) FY 2024-25
18 19 20 21 22 23 24
(H1Actual 5 3 2 Projected
+ H2 Proj)
Segregated AP 4,688.38 4222.50 4721.80 4407.61 4228.544 4802.75 4,286.30 0.48% 0.57% 4.39% 4,329.16
feeders
Normative 3,938.24 3,546.90 3,966.31 3,702.39 3,551.98 4,034.31 3,600.49 3,636.49
consumption
@16% of loss
Billing on other 48.18 44.53 47.36 46.46 20.979 18.05 14.78 14.92
than AP feeder
CAGR=1%
Other category 22.95 19.23 13.79 14.45 15.49 15.45 17.39 17.57
consumption on
AP Feeders
Net Normative 3,963.47 3,572.20 3,999.88 3,734.40 3,557.47 4,036.91 3,597.87 3,633.85
AP Consumption
DHBVNL
Table: AP Sales Projection FY 2024-25 of DHBVNL (MU)
Consumption FY 2017- FY 2018- FY 2019- FY 2020- FY 2021- FY 2022- FY 2023- CAGR (2017-18 to 2022-23) FY 2024-25
18 19 20 21 22 23 24
(H1Actual 5 3 2 Projected
+ H2 Proj)
Segregated AP 6,336.73 5979.70 5864.32 6124.84 5541.5 6418.35 6,197.03 0.26% 3.05% 2.37% 6,259.00
feeders
Normative 5,322.85 5,022.95 4,926.03 5,144.87 4,654.86 5,391.42 5,205.51 5,257.56
consumption
@16% of loss
Billing on other 134.44 187.14 235.25 235.97 545.855 304.74 547.33 552.80
than AP feeder
CAGR=1%
Other category 68.21 61.02 69.41 63.37 69.961 91.37 117.82 119.00
consumption on
AP Feeders
Net Normative 5,389.08 5,149.07 5,091.87 5,317.47 5,130.75 5,604.79 5,635.01 5,691.36
AP Consumption
The Commission after due deliberations and analysis of time series data for AP sales approves
the AP sales of DISCOMs for FY 2024-25 as tabulated below against DISCOMs proposed 3722.63
MU by UHBVNL and 6683.01 MU by DHBVNL for the year:-

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Table: AP Sales for FY 2024-25 (MU)

Sr. No. AP sales MU
1 UHBVNL 3633.85
2 DHBVNL 5691.36
3 Total AP Sales of DISCOMs (1+2) 9325.21
5.3 Assessment of Energy Sales for FY 2024-25 (Other Consumer Categories)
UHBVNL
UHBVNL, in its petition, has submitted that FY 2022-23 is considered as the base-year for
projecting the energy sales for APR (FY 2023-24) and thereafter for ARR (FY 2024-25) years.
Hon’ble Commission created new consumer categories by merging the previous categories as
per tariff order dated 30.03.2021. In the ibid Tariff Order, the Hon’ble Commission merged NDS
category (upto 50 kW) & LT Industry (upto 50 kW) into LT supply. Further, NDS category (above
50 kW), HT Industry (above 50 kW) & Metro/Railway Traction has been merged into HT Supply.
Due to non-availability of historical data of such consumer categories, sales estimates for FY
2024-25 have been calculated after merging the categories mentioned in the tariff order dated
15.02.2023. Accordingly, category-wise energy sales for FY 2024-25 are projected based on 2-to-
7 years Compound Annual Growth Rate (CAGR) on energy sales of FY 2023-24. For estimation of
CAGR, FY2023-24 has been considered as the end year. Category wise CAGR of energy sales is
tabulated as follows: -

Proposed CAGR for projecting Energy Sales by UHBVNL (%age)

Selected
Category 2 years 3 years 5 years 7years
CAGR
Domestic 9.64% 9.97% 11.84% 11.81% 11.81%
HT Supply 11.93% 17.09% 10.87% 11.63% 11.63%
LT Supply 12.56% -0.29% 0.73% 2.71% 10.00%
Agriculture 1.12% -0.01% 0.35% -1.56% 2.64%
Bulk Supply 11.74% 7.07% 3.81% 3.35% 3.35%
Street Lighting 7.75% -4.19% -0.14% 5.24% 5.24%
PWW/MITC 0.53% 8.97% 7.44% 7.63% 7.63%

In view of above, the category wise energy sales for the ensuing year, i.e., FY 2024-25 are
tabulated as follows:

Projected Category wise sales for FY 2024-25 by UHBVNL (in MU)

Category CAGR FY 2024-25 (Proposed)
Domestic 11.81% 7,888.56
HT Supply 11.63% 9,275.13
LT Supply 10.00% 2,782.77

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Category CAGR FY 2024-25 (Proposed)

Agriculture 2.64% 3,722.63
Bulk Supply 3.35% 393.07
Street Lighting 5.24% 78.63
PWW/ MITC 7.63% 729.82
Total 24,870.61
DHBVNL
DHBVNL, in its petition, has submitted that the Hon'ble Commission in Tariff Order FY 2021-22
has merged NDS category (upto 50 kW) & LT Industry (upto 50 kW) into LT supply. Further, NDS
category (above 50 kW), LT Industry (above 50 kW) & Metro Supply has been merged into HT
supply. Since, the historical data is not available in the newly formed categorization, hence, the
projections have been made based on the previous year categorization.

Sales for FY 2024-25 is estimated based on 2 to 7 years CAGR on the projected sales of FY 2023-
24. The Category wise 2 to 7 years CAGR is shown in table below:

Proposed CAGR of Annual Sales of DHBVNL (in %)

Sr. No. Category 2 years 3 years 5 Years 7 years
1 Domestic Supply 13.94% 10.66% 11.72% 11.07%
2 LT Supply 20.16% 5.85% 5.84% 6.70%
3 HT Supply 24.44% 10.87% 7.31% 8.55%
4 Agriculture -1.97% -0.83% 0.09% 2.43%
5 Bulk Supply 10.80% 8.15% 10.39% 12.65%
6 Public Water Works/Lift Irrigation/SL 3.36% 2.68% 3.48% 6.22%
Following are the category wise energy sales projected by DHBVNL for FY 2024-25:

Energy Sales Projection for FY 2024-25 (MUs)

Sr. No. Category CAGR FY 2024-25
1 Domestic Supply 11.1% 10,024.61
2 LT Supply 7.5% 5,868.64
3 HT Supply 10.9% 10,288.29
4 Agriculture 2.4% 6,683.01
5 Bulk Supply 12.7% 1,555.34
6 Public Water Works/Lift Irrigation/SL 6.2% 1,171.48
7 Total 35,591.37
In view of above projections, the Discoms have prayed that the Hon'ble Commission may
approve the category wise energy sales projections for FY 2024-25, as presented above.

The Commission has perused the methodology adopted by the petitioner(s) for projecting
consumer category wise sales for the FY 2024-25. Hence, the petitioner(s) adopted CAGR varying
from 2% to 13%. The Commission observed that there is no stable growth pattern and

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accordingly, the petitioners have projected the sales based on 7-year CAGR or some random
growth rate has been considered.

The Commission, has moderated the sales growth rates based on 5-year CAGR, considering a
nominal growth. The AP sales have been projected based on data emanating from the 11 kV
segregated feeders. Resultantly, the revised sales projected by the Discoms and that approved
by the Commission is presented in the table below: -

Sales of Categories other than AP: The Commission, for projection of consumer category wise
sales for the FY 2024-25, as per past practice, has considered a uniform CAGR and the same is
taken as 5-year CAGR. However, for HT categories, the sales projected by the Discoms have been
considered, as the data available on sales, contract demand, number of HT consumers and
expected new connections in the HT supply industry is expected to provide a more reliable
projections for this category. The following table presents the consumer category wise sales
approved by the Commission for the FY 2024-25: -

Projected Approved for 2024-25 Total (MUs)

Category of UHBVNL DHBVNL UHBVNL DHBVNL Projected Approved
Consumers (MU) (MU) (MU) (MU)
Domestic 7888.56 10024.61 8403.76 10810.47 17913.17 19214.23
Non - Domestic 0.00 4615.04 0.00 4491.57 4615.04 4491.57
HT Industries 9275.13 10180.38 9275.13 10180.38 19455.50 19455.50
LT Industries 2782.77 1253.60 3347.24 1297.01 4036.37 4644.25
Lift Irrigation 0.00 241.23 0.00 226.21 241.23 226.21
Agro Industry 19.17 19.17 19.17
Industries /FPO
(New Category
upto 20 kW)
Agriculture 3722.63 6663.84 3633.85 5691.36 10386.46 9325.21
(Metered and
unmetered)
Bulk Supply 393.07 1555.34 449.99 1558.67 1948.42 2008.66
Railway Traction 0.00 0.00 0.00 0.00 0.00 0.00
MITC 0.00 107.91 0.00 101.70 107.91 101.70
Street Lighting 78.63 100.81 67.30 92.55 179.45 159.85
Public Water 729.82 829.43 801.20 824.27 1559.25 1625.47
Works
Total 24870.61 35591.37 25978.47 35293.36 60461.98 61271.83

The aforesaid consumer category wise sales have been considered for estimating revenue at the
existing tariff, of the Discoms. However, the Commission had rationalized certain tariff category

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and classified the same into HT and LT Supply depending on the voltage of at which consumers
in different categories were taking supply. Hence, the same practice shall continue. The Discoms,
may continue collating data accordingly i.e. as per the merged categories instead of the
categories that have been dispensed with.

5.4 Power Purchase Quantum and Cost

Projections by the Discoms (FY 2024-25): -
In the petition(s) under consideration of the Commission, it is observed that the Discoms have
estimated the energy availability from the approved generating sources viz. NTPC, NHPC, HPGCL,
NPCIL, UMPPs, IPPs, BBMB, SJVNL, THDC, DVC and other renewable generating stations. Any
surplus during real time operation is banked or traded and any deficit is purchased through short-
term sources to meet the requisite energy demand. Discoms have submitted that the power
purchase expenses shall be estimated based on the energy available from the ‘Must Run’ plants
(includes Hydro, Small Hydro, Nuclear, RE sources) and energy available from the Thermal
Generating stations based on Merit Order Dispatch (MOD) at Inter-State and Intra-State level.
Further, energy from upcoming plants is assessed on normative basis as per planned COD.

Thus, with this background, the estimated energy sales to consumers for the FY 2024-25 is
expected to be met by the long-term Generators/Traders with whom Haryana has a valid PPA
first, followed by short-term procurement in case of deficit situation occurring in a specific
month. As mentioned in the above paragraph, the procurement is prioritized from the ‘Must
Run’ plants followed by the Thermal generating stations, whose energy availability is estimated
at generation ex-bus based on the respective generating station MW availability and PLF. It has
been submitted that the MOD for the Thermal Generating Station is worked out by ranking them
with respect to their energy/variable charges.

The Discoms have further submitted that the variable charges (Rs/kWh) for the existing
generating stations are considered with 2% escalation over the variable charges (Rs/kWh) of FY
2023-24. Further, for the new generating stations, tariff as determined by CERC/SERC or through
competitive bidding on actual basis have been considered for the purpose of estimation of
variable cost. The Fixed Cost of the generating plants for FY 2024-25 have been estimated by
escalating the estimated fixed cost of FY 2023-24 with 5%. Further, for Cogeneration, Biomass,
Biogas, Waste to Energy and Solar Plants under PM KUSUM, the tariff approved or adopted by

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the Hon’ble Commission has been considered for estimating the power purchase cost of these
power plants for the ARR year by the Discoms.

UHBVNL, in its petition, added that under the Govt. of India ambitious plan, India plants to set
up 500 GW of renewable capacity by 2030. Accordingly, in line with the Renewable Purchase
Obligation set by the Hon’ble Commission, the renewable capacity from SECI and other sources
is tied up. These power from these plants is sourced through competitive bidding and thus will
eventually reduce the average power purchase cost of Haryana Discoms. In addition to the
above, UHBVNL submitted that no blending impact has been considered during FY 2024-25 in
case of Thermal Generating Stations for estimating the Power Purchase Cost. Further, the
petitioner in this present ARR petition is not claiming any ‘change in law’ or prior period expenses
impact in order to avoid over-estimation of the overall Power Purchase Cost, which may also
increase the overall ARR of the Petitioner. However, the Nigam seeks the liberty from the Hon’ble
Commission to claim such expenses on actual basis at the time of True-up.

The Discoms have further submitted that Inter-state transmission charges for ARR year have
been calculated by escalating the estimated Inter-state transmission charges for FY 2023-24 by
4.78% (as published by CERC on 05.10.2023). Intra-state transmission charges for ARR year have
been calculated by considering a moderate 5.00% escalation on the estimated Intra-state
Transmission Charges for FY 2023-24.

UHBVNL
UHBVNL, in the present petition, has submitted that the estimated average power purchase cost
through short-term is Rs 6.48/Unit. Total power purchase cost estimated for ARR year, inclusive
of inter and intra-state transmission charges, as follows:

Total power purchase cost estimated for ARR year, inclusive of inter and intra-state transmission
charges, is tabulated as follows:

Proposed Power Purchase Cost UHBVNL (FY 2024-25) (Rs Cr.)

Particulars Units FY 2024-25
Power Purchase Cost Rs. Cr. 12,293.34
Inter-State Transmission Rs. Cr. 957.72
Intra-state Transmission Rs. Cr. 967.42
Total Power Purchase cost Rs. Cr. 14,218.48
PP Quantum MU 29,317.33
Average power purchase cost Rs/kWh 4.85

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DHBVNL
DHBVNL, in the present petition, has submitted that the total power purchase cost estimated for
ARR year, inclusive of inter and intra-state transmission charges, as follows:

Proposed Power Purchase Cost DHBVNL (FY 2024-25) (Rs Cr.)

Particulars FY 2024-25
Power Purchase Cost (Rs. Crore) 17,581.01
Power Purchase Quantum (MUs) 41,954.90
Average power purchase cost (Rs./kWh) 4.19
Interstate Transmission (Rs. Crore) 1,382.07
Intra-state Transmission (Rs. Crore) 1,384.44
Total Power Purchase cost (Rs. Crore) 20,347.52
Average Power Purchase including Transmission Cost 4.85
In view of above, the Discoms prayed to allow the power purchase cost for FY 2024-25 as
projected in above Table.

Commission’s Estimate of Power Purchase Quantum and Cost: -

The Commission has taken note of the methodology for projecting availability of power by the
Discoms for the FY 2024-25 as mentioned in the preceding paragraphs. The Commission has
considered the submissions and is of the view that the Central Electricity Authority (CEA), in
consultation with the generators, publishes a month wise schedule of expected generation after
considering the planned shutdown as well as commissioning of new units. Hence, as per past
practice, the Commission is of the considered view that the CEA’s generation targets for the
generators located in different corners of the country is a reliable estimate to arrive at projected
power availability for the Discoms in Haryana in the FY 2024-25. However, is observes that as of
now CEA’s generation targets are available for the FY 2023-24 and not for the FY 2024-25 i.e.
the ARR year. Further, the actual source wise power purchase quantum and cost is also not
available for the entire year. Consequently, the Commission has adjusted the FY 2023-24
generation target for the trend in source wise actual drawl, auxiliary consumption, free home
state shares wherever applicable. In the case of new sources and RE sources, the Commission
has considered the quantum as proposed and in the case of HPGCL the same has been considered
as per the Commission’s order in the matter of determination of generation tariff for various
power plants owned and operated by the intrastate generator. Additionally, for working out the
cost, the Commission has considered the PPA rates, source wise actual fixed cost and average

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Energy Charges incurred in the FY 2023-24, adjusted for the anticipated increase as also proposed
by the Discoms in the present petition under consideration. Further, the Commission has not
considered payment of any fixed cost (as proposed by the petitioner) for power from CGPL
(Mundra) sources as the Discoms have not projected power availability from the same on the
plea that the said generator is not ready to make power available in accordance with the
concluded PPA. Fixed cost from NTPC sources (gas based) i.e. Anta , Auraiya, Dadri, Faridabad,
fixed cost for these stations have been allowed but restricted to the previous years level as per
the data available in the Commission.
The source wise quantum and cost of power assessed above, shall not be construed as approval
of a source i.e. generating stations / traders. The Discoms shall ensure that power is procured
only from the sources approved by the Commission and for which a valid PPA (as approved by
the Commission) exists. It is added that the Commission has not approved any short-term
purchases as proposed by the Discoms as this would depend on quite a few factors, difficult to
project, at this stage. However, the Discoms may manage the day to day exigencies by selling
/ buying power on day ahead or real time basis as the situation may warrant.
A summary of source wise power purchase quantum and cost approved by the Commission is
presented in the table that follows: -
HERC Approved Power Purchase Quantum & Cost FY 2024-25
Source Quantum ECR (RS FC (RS Total PPC (RS ECR (Rs /
(MUs) CRORE) CRORE) CRORE) kWh)
NTPC
Anta CCGT 0.00 0.00 2.05 2.05
Auriya CCGT 0.00 0.00 20.70 20.70
Dadri CCGT 0.00 0.00 3.13 3.13 Not
Faridabad Gas 0.00 0.00 142.78 142.78 Scheduled
Feroz Gandhi Unchahar-1 TPS 18.79 8.70 12.47 21.17 4.63
Feroz Gandhi Unchahar-2 TPS 154.59 40.03 43.05 83.08 2.59
Feroz Gandhi Unchahar-3 TPS 20.48 9.80 14.67 24.47 4.79
Feroz Gandhi Unchahar-4 TPS 111.05 54.24 55.39 109.63 4.88
Farraka STPS 88.86 21.70 18.42 40.12 2.44
Kahalgaon-1 TPS 108.71 25.28 38.26 63.54 2.33
Kahalgaon-2 TPS 331.07 67.09 51.59 118.68 2.03
Koldam HYDRO 356.06 90.21 110.35 200.56 2.53
Rihand Thermal Power St.-1 501.00 64.50 64.99 129.49 1.29
Rihand Thermal Power St.-2 439.00 56.57 58.77 115.34 1.29
Rihand Thermal Power St.-3 432.00 69.95 72.29 142.24 1.62
Singrauli Super Thermal 1476.00 185.61 202.79 388.40 1.26
NHPC
BAIRASUIL HEP 183.88 28.96 28.53 57.49 1.58
SALAL HEP 602.34 78.42 92.29 170.71 1.30

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Source Quantum ECR (RS FC (RS Total PPC (RS ECR (Rs /
(MUs) CRORE) CRORE) CRORE) kWh)
TANAKPUR HEP 27.82 8.82 8.79 17.61 3.17
CHAMERA-I HEP 441.26 40.77 50.36 91.13 0.92
URI HEP 188.92 22.61 24.13 46.74 1.20
CHAMERA-II HEP 70.79 7.66 11.89 19.55 1.08
DHAULIGANGA HEP 75.95 10.85 14.08 24.93 1.43
DHULHASTI HEP 108.03 26.66 43.66 70.32 2.47
SEWA-II HEP 25.75 7.30 13.11 20.41 2.84
KISHANGANGA HEP 0.00 0.00 0.00 0.00
CHAMERA III HEP 80.92 23.11 28.72 51.83 2.86
PARBATI III HEP 63.23 10.82 15.40 26.22 1.71
URI-II HEP 78.77 18.20 31.86 50.06 2.31
SJVNL
SJVNL(Nathhpa Jhakri) HEP 335.94 42.67 55.39 98.06 1.27
SJVNL (RAMPUR) HEP 91.17 20.05 26.45 46.50 2.20
THDCL
THDC(Tehri) HEP 210.87 57.88 60.31 118.19 2.74
THDC KOTESHWAR HEP 48.35 18.26 19.36 37.62 3.78
NPCIL
RAPS NUCLEAR 545.00 242.62 119.87 362.49 4.45
NAPS NUCLEAR 196.52 69.70 41.74 111.44 3.55
BBMB HEP 3295.45 0.00 90.52 90.52 0.00
OTHER LONG-TERM SOURCES
PTC TALA HEP 51.08 10.24 4.77 15.01 2.00
PDC J&K HEP as proposed 837.32 323.04 241.58 564.62 3.86
Aravali Co. Pvt. Ltd. STPS 2406.00 957.30 967.22 1924.52 3.98
JHAJJAR POWER LTD. (CLP) STPS 8292.98 3364.39 2058.08 5422.47 4.06
PRAGATI POWER GAS 6.76 4.28 95.57 99.85 6.33
Coastal Gujrat Power Ltd. STPS 0 0 0 0.00
ADANI POWER LTD TPS 9824.000 2539.820 1682.690 4222.51 2.59
SASAN POWER LIMITED TPS 3426.000 455.850 282.340 738.19 1.33
PTC GMR KAMALANGA TPS 1934.000 514.210 439.850 954.06 2.66
PTC KARCHAMWANGTOO HEP 817.938 230.560 278.320 508.88 2.82
PTC Lanco Amarkantak(Linkage)
TPS 1840.000 474.010 313.700 787.71 2.58
DVC MEJIA TPS 288.670 99.510 182.090 281.60 3.45
DVC KODERMA TPS 701.780 233.550 183.470 417.02 3.33
DVC Raghunathpur TPS 701.770 234.110 158.780 392.89 3.34
NEEPCO HEP 971.380 384.390 112.310 496.70 3.96
GATI HEP 971.600 402.750 0.000 402.75 4.15
DANS HEP 399.340 162.510 0.000 162.51 4.07
SHIGA HEP 366.850 168.490 0.000 168.49 4.59
IA HYDRO 268.780 125.140 0.000 125.14 4.66
HPGCL
HPGCL PANIPAT UNIT-VI TPS 1422.930 646.661 160.148 806.81 4.54
HPGCL PANIPAT UNIT-VII TPS 1703.270 775.856 186.309 962.17 4.56
HPGCL PANIPAT UNIT-VII TPS 1703.270 775.856 188.090 963.95 4.56
HPGCL DCRTPP UNIT-1 TPS 2043.930 861.403 199.268 1060.67 4.21
HPGCL DCRTPP UNIT-2 TPS 2043.930 861.403 199.882 1061.29 4.21
HPGCL RGTPP UNIT-1 TPS 4199.540 1762.249 304.045 2066.29 4.20
HPGCL RGTPP UNIT-2 TPS 4199.540 1762.249 306.270 2068.52 4.20
WESTERN YAMUNA CANAL HEP 232.7 0 40.298 40.30 0.00

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Source Quantum ECR (RS FC (RS Total PPC (RS ECR (Rs /
(MUs) CRORE) CRORE) CRORE) kWh)
RENEWABLE SOURCES
P&R GOGRIPUR SMALL HYDRO 9.72 3.94 0 3.94 4.05
Bhoruka Power Corps. Ltd.
SMALL HYDRO 29.14 5.59 0 5.59 1.92
SHAHBAD SUGAR MILL COGEN 46.72 19.28 0 19.28 4.13
Naraingarh Sugar Mill COGEN 29.74 16.53 0 16.53 5.56
KARNAL CO. SUGAR MILL
COGEN 28.91 11.01 0 11.01 3.81
PANIPAT CO. SUGAR MILL
COGEN 45.99 17.6 0 17.60 3.83
CH. DEVI LAL SUGAR MILL
COGEN 2.99 1.24 0 1.24 4.15
HARYANA CO. SUGAR MILL
COGEN 20.28 12.33 0 12.33 6.08
HAFED SUGAR MILL COGEN 2.82 1.16 0 1.16 4.11
PURI OIL MILL SMALL HYDRO 13.59 5.09 0 5.09 3.75
SOLAR
SDS SOLAR PVT LTD. DH SOLAR 1.43 0.83 0 0.83 5.80
EON SOLAR 1.14 0.66 0 0.66 5.79
CHANDRALEELA SOLAR DH 0.82 0.48 0 0.48 5.85
SUKHBIR SOLAR 1.05 0.61 0 0.61 5.81
XION ENERGY SOLAR 1.17 0.68 0 0.68 5.81
SIWANA SOLAR POWER SOLAR 6.51 3.58 0 3.58 5.50
H.R. MINERAL SOLAR UH 1.37 0.8 0 0.80 5.84
TAYAL & CO SOLAR UH SOLAR 1.17 0.68 0 0.68 5.81
VKG SOLAR UH SOLAR 0.88 0.51 0 0.51 5.80
Utrecht Solar Pvt. Ltd. SOLAR 1.48 0.85 0 0.85 5.74
SUBHASH INFRA SOLAR 1.53 0.78 0 0.78 5.10
JBM Solar 30.85 17.87 0 17.87 5.79
Balarch Solar 1.63 0.95 0 0.95 5.83
Greenyana Solar 17.84 4.55 0 4.55 2.55
Raj Waste Treat Pvt. Ltd. 2.63 0.83 0 0.83 3.16
Deepan Godara 0.34 0.1 0 0.10 2.94
Gio Tech 1.68 0.51 0 0.51 3.04
HPGCL-Solar 16.19 8.12 0 8.12 5.02
Amplus SOLAR 108.99 27.57 0 27.57 2.53
Avaada Green SOLAR 70.43 20.54 0 20.54 2.92
Avaada RJHN SOLAR 528.75 152.57 0 152.57 2.89
LR Engergy SOLAR 33.09 8.73 0 8.73 2.64
SECI WIND / SOLAR /HYBRID
SECI Wind T-II@2.71 274.57 78.65 0 78.65 2.86
SECI Wind T-III @ 2.51 843.8 223.86 0 223.86 2.65
SECI Wind-Inter @2.72 82.07 23.67 0 23.67 2.88
SECI Wind-T-V 718.36 215.3 0 215.30 3.00
SECI-Hybrid 308.35 89.88 0 89.88 2.91
SECI Solar T-1 @ 2.60 239.76 65.89 0 65.89 2.75
SECI Solar T-IV Mega Surya@
2.61 577.06 159.19 0 159.19 2.76
SECI Solar @ 5.5 138.69 80.62 11.41 92.03 5.81
BIOMASS / PADDY STUBBLE
STAR WIRE INDIA BIOMASS 69.38 49.89 0 49.89 7.19
GEMCO ENERGY LTD. BIOMASS 38.54 27.72 0 27.72 7.19

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Source Quantum ECR (RS FC (RS Total PPC (RS ECR (Rs /
(MUs) CRORE) CRORE) CRORE) kWh)
Oasis Commercial Pvt. Ltd.
BIOMASS 16.65 10.63 0 10.63 6.38
JBM Environment WtE 53.38 37.22 0 37.22 6.97
SRI JYOTI Biomass 37.44 28.19 0 28.19 7.53
Sukhbir Agro Energy Ltd Paddy
Stubble 98.55 58.54 0 58.54 5.94
Hind Samachar Ltd Paddy
Stubble 98.55 58.18 0 58.18 5.90
k2 power Biogas 4.38 2.99 0 2.99 6.83
Mor Bio Energy Biogas 2.1 1.77 0 1.77 8.43
OTHERS
Alfanar Nefra-590 MW (Tranche
V) 617.34 181.68 0 181.68 2.94
Fatehabad Bio Energy Paddy
Stubble 63.83 44.75 0 44.75 7.01
Jind Bio Energy Paddy Stubble 63.83 44.81 0 44.81 7.02
RSL Distillery Pvt. Ltd. 19.35 13.59 0 13.59 7.02
ISTS Solar Projects 3000 MW, T-
II 1024.11 266.37 0 266.37 2.60
EcoGreen Energy Gurgaon
Faridabad WtE 151.11 106.38 0 106.38 7.04
PTC India 360 MW 451.81 266.11 0 266.11 5.89
Tehri PSP (Uttranachal)-THDC 432.75 269.06 0 269.06 6.22
Assured peak power (wind) 426.26 178.01 0 178.01 4.18
Hybrid Power from SECI (wind) 786.99 198.98 0 198.98 2.53
Assured Peak Power (Solar) 106.3 44.39 0 44.39 4.18
Hybrid Power from SECI (Solar) 1593.83 398.04 0 398.04 2.50
NVVN Nepal 2 352.04 198.82 0 198.82 5.65
TOTAL 73116 23329 10285 33613 3.19

5.5 Interstate Transmission and SLDC Cost

The Discoms, in the present petition(s), have submitted that Inter-state transmission charges for
the ARR year are calculated by escalating the estimated Inter-state transmission charges for the
FY 2023-24 by 4.78% as published by CERC on 05.10.2023.

5.6 Intrastate Transmission and SLDC Cost

The Discoms, in the present petition(s), have submitted that Intra-state transmission charges for
ARR year are calculated by considering a moderate 5.00% escalation on the estimated Intra-state
Transmission Charges for FY 2023-24.
The Commission has considered the submissions of the distribution licensee(s) and observes
that, vide its Order dated 16th February, 2024 on HVPNL’s Transmission Tariff and SLDC charges
petition for the FY 2024-25, has approved Transmission tariff and SLDC charges to be recovered
by HVPNL from the beneficiaries mainly the Discoms i.e. UHBVNL and DHBVNL. The intrastate
transmission charges approved include the ‘Unitary Charge’ arising out of transmission project
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commissioned through Public Private Partnership (PPP) between HVPNL and M/s Jhajjar KT
Transco Private Limited. The details including monthly recovery of the transmission and SLDC
charges from various beneficiates including the Discoms have been given in the ibid order.
Hence, the same is not being reproduced here.
The transmission and SLDC Charges, as determined by the Commission in the ibid Order, shall
form part of the ARR of the Discoms for the FY 2024-25. In addition to the above and keeping in
view the surplus power availability scenario prevailing in Haryana especially during the off peak
period, the Commission directs that the Discoms shall not procure any additional power over and
above the quantum approved in the PPA that may be available to it from the un-allocated share
/ share relinquished by any other State in the Central Generating Power Stations in case it does
not fall in the merit order dispatch (MOD). The Commission thereto shall disallow all such power
procurements and the cost thereto. Additionally, while resorting to bidding or calling for
expression of interest for power procurement the Discoms must ensure that the power under
PPAs already approved by the Commission materializes and also the intra-State generator i.e.
HPGCL’s power plants are scheduled at least up to the critical minimum threshold before
considering backing down. The DISCOMs are directed to perform cost benefit analysis including
trade-off between purchase of REC and RE Power before rushing with proposal to procure RE
Power.

5.7 Interstate Transmission losses and Intrastate transmission losses

Based on the transmission loss details published on Power System Operation Corporation Ltd.
(POSOCO) website, the interstate losses are being determined by the Discoms on notional basis
i.e. based on of last 52 weeks data, the average loss level works out to 3.62%. Thus, Discoms have
prayed that the same may be considered for projecting power purchase cost for the ARR year.
However, Intrastate transmission losses for ARR year are considered at 2.05%, the same as
approved by the Hon'ble Commission in the Tariff Order dated 15.02.2024, as per the specified
trajectory under Regulation 45.4 of HERC MYT Regulations 2019.

5.8 Energy Balance

UHBVNL
Energy balance for ARR year, based on energy availability, transmission losses, distribution losses
and energy sales projected by UHBVNL has been tabulated as follows: -

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UHBVNL
Projected Energy Balance for FY 2024-25
Energy Balance-UH Units FY 2024-25
Energy Requirement
Energy Sales MUs 24871
T&D loss %age 10.75%
Energy Input at Discom Periphery MUs 27866
Intra- State Transmission Loss %age 2.05%
Energy Requirement at State Periphery MUs 28449

Energy Purchase
Total Energy Available (Ex Bus) MUs 29317
Inter-state Power Purchase considering MoD MUs 23943
Inter -state transmission losses %age 3.62%
Inter-state Power Purchase at State Periphery MUs 23075
Intra-state Power Purchase Considering MoD MUs 5374
Power Purchase at State Periphery MUs 28449

DHBVNL:
DHBVNL has submitted the projected energy balance for the FY 2024-25 as under:-

Projected Energy Balance for FY 2024-25 DHBVNL

Particulars Units FY 2024-25
Energy Sales MUs 35,591.37
T&D loss % 10.75%
Energy Input at Discoms Periphery MUs 39,878.29
Intra- State Transmission Loss % 2.05%
Energy Input at State Periphery MUs 40,712.90

Total Energy Available (Ex-Bus) MUs 41,954.90

Inter-state Power Purchase considering MoD MUs 34,263.82
Inter State transmission losses % 3.62%
Inter-state Power Purchase at State Periphery MUs 33,021.82
Intra state Power Purchase Considering MoD MUs 7,691.08
Power Purchase at State Periphery MUs 40,712.90
Surplus MUs 0.00
The Commission has considered the above ‘Energy Balance’ as submitted by the distribution
licensees (UHBVNL and DHBVNL). However, as the underlying data on sales, losses, quantum of
power purchase projected by the Commission is different, hence, the Energy Balance as
approved by the Commission for the FY 2024-25 is tabulated below: -

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Energy available for Sale to the Distribution Licensees for the FY 2024-25
Sr.
Particulars Units UHBVNL DHBVNL Total
No.
Gross energy procured from outside
1 MU 13,064.68 16,751.71 39,269.73
the state sources
2 Interstate sale / banking # MU 755.54514 1026.4549 1,782.00
Energy procured from outside the
3 state sources net of interstate sale / MU 12,309.13 15,725.26 37,487.73
banking
4 Inter-state transmission losses % 3.62% 3.62% 3.62%
5 Inter-state transmission losses MU 445.59051 569.25439 1357.0559
Net energy available from outside
6 MU 12,304.67 15,719.57 36,183.16
the state
Add energy generated within the
7 MU 13705 19,616.37 33,322
state
Energy available at Haryana
8 MU 26,009.81 35,335.93 69,504.66
Boundary (6+7)
9 Intra-state transmission losses % 2.05% 2.05% 2.05%
10 Intra-state transmission losses MU 533.20105 724.38664 1424.8455
11 Energy at Discom Boundary MU 26,004.48 35,328.69 68,079.81
12 Distribution loss % 10% 10% 10%
13 Distribution loss units MU 2600.4475 3532.869 6807.9813
Units available for sale to DISCOMS/
14 HERC approved Sales to the MU 25,978.47 35,293.36 61,271.83
electricity consumers in FY 2024-25
Total Energy Purchase MU 30072.60 43043.38 73115.98
Power Purchase Cost Rs. Mln 138265.82 197866.90 336132.72
15 Average rate Rs /kWh 4.60 4.60 4.60

Total power purchase cost

Fixed cost Rs Mln 102846.50
Variable cost of sold units by
Rs. Mln 217217.67
DISCOMS(ECR*11)
16 Cost of Power Rs. Mln 125275.94 155026.08 320064.17
Total Transmission and SLDC
17 Rs. Mln 18919.607 24674.693 43594.3
Charges
18 Total Cost (16+17) Rs. Mln 144195.54 179700.77 363658.47
Units purchased for units sold by
18A MU 26,009.81 35,335.93 69,504.66
Discoms (8)
Average Power Purchase Rate
19 Rs/kWh 5.54 5.09 5.23
(18/18A)
Bulk Supply Rate at Discoms
20 Rs/kWh 5.55 5.09 5.34
Boundary (18/11)
# Interstate sale / banking has been taken as per the audited figures of FY 2022-23, in absence of the
actual data and bifurcated into Discoms based on current allocation proposed by the Discoms.

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5.9 Operation & Maintenance Expenses (O&M)

The Operation & Maintenance (O&M) expenses comprise of Employees expenses, Repair &
Maintenance expenses, and Administrative & General expenses. As per the regulation 8.3.3 of
HERC MYT Regulations, 2019, O&M expenses, excluding the expenses towards ‘terminal
benefits’ are controllable items. The Commission observes as under:

i. Employees Expenses consist of salaries, dearness allowance, bonus, terminal benefits in

the form of pension & gratuity, leave encashment and staff welfare expenses.

ii. Repairs and Maintenance expenses include regular expenditure made for improvement
of system reliability and quality of power supply. These expenses are important in view
of the system maintenance and loss reduction within the distribution network.

iii. Administrative expenses mainly comprise of rents, telephone and other communication
expenses, professional charges, conveyance and travelling allowances.

According to Regulation 57.4 of HERC MYT Regulations, 2019, and its amendment thereof,
component wise O&M expenses have been elaborately in the subsequent sections. The relevant
extract of the Regulation is reproduced as under:

“The actual audited expenses for the financial year preceding the base year, subject to prudence
check, shall be escalated at the escalation factor of 4% to arrive at the Employee Costs and
Administrative and general Costs for the base year of the control period. The O&M expenses for
the nth year of the control period shall be approved based on the formula given below."

O&Mn = (R&Mn + EMPn + A&Gn)*(1-Xn)+Terminal Liabilities

Where,

• R&Mn – Repair and Maintenance Costs of the Distribution Licensee(s) for the nth year;
• EMPn – Employee Costs of the Distribution Licensee(s) for the nth year excluding
terminal liabilities;
• A&Gn – Administrative and General Costs of the Distribution Licensee(s) for the nth
year;
The above components shall be computed in the following manner.

(a) R&Mn = K * GFA * INDXn/ INDXn-1

Where,

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• ‘K’ is a constant (expressed in %) governing the relationship between

O&M costs and Gross Fixed Assets (GFA) for the nth year. The value
of K will be 1.65% for DHBVNL and UHBVNL respectively for the
entire control period;
• ‘GFA’ is the average value of the gross fixed asset of the nth year.
• ‘INDXn’ means the inflation factor for the nth year as defined herein
after.
(b) EMPn (excluding terminal liabilities) + A&Gn = (EMPn-1+ A&Gn-1)*(INDXn/ INDXn-1)
Where,

• INDXn – Inflation Factor to be used for indexing the Employee Cost

and A&G cost. This will be a combination of the Consumer Price Index
(CPI) and the Wholesale Price Index (WPI) for immediately preceding
year and shall be calculated as under:
• INDXn = 0.55*CPIn +0.45*WPIn
Note 1: For the purpose of estimation, the same INDXn value shall be used
for all years of the control period. However, the Commission shall consider
the actual values of the INDXn at the end of each year during the annual
performance review exercise and true-up the employee cost and A&G
expenses on account of this variation.

Note 2: Any variation in employee cost and A&G cost on account of

reasons beyond variation in INDXn shall be subject to the incentive and
penalty framework specified in Regulation 12.

Note 3: As and when any material price index specific to power sector or
a more relevant Index becomes available, the same shall replace the
Index used for working out R&M cost.

Note 4: Terminal liabilities shall be approved as per actual expenditure

incurred by the distribution licensee or established through actuarial
valuation for the ensuing year.

Note 5: O&M expenses made on account of extraordinary situations (if

any) shall be submitted to Commission for its approval. Such expenses
shall be filed separately and will not be subjected to incentive and penalty

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framework. The approved amount by the Commission shall be trued up in

the annual performance review.

Note 6: Changes in the pay scales of employees necessitated on account

of pay revision by Pay Commission or by the State Government orders
shall be considered by the Commission for true-up during the annual
performance review.

Note 7: Source for CPI and WPI calculation as under:

Wholesale Price Index numbers as per Office of Economic Advisor of

Government of India in the previous year;

Consumer Price Index for Industrial Workers (all India) as per Labour
Bureau, Government of India in the previous year

(c) Xn is an efficiency factor for nth year

The Value of Xn will be determined by the Commission in the MYT order
for the control period.
Computation of Inflation Factor
The Discoms have submitted that as per Regulation 57.4 of HERC MYT Regulations, 2019,
Indexation Factor is calculated for ARR year FY 2024-25. Average yearly inflation of FY 2021-22
and FY 2022-23 is derived based on the monthly Wholesale Price Index (WPI) as per the Office of
Economic Advisor, Ministry of Commerce and Industry, Government of India and monthly
Consumer Price Index (CPI) for Industrial Workers (all-India) of the respective financial year as
per the Labor Bureau, Government of India. Details of relevant indices for requisite period are
Tabulated as follows:

Based on the CPI and WPI indices, Inflation factor for ARR year has been calculated as per the
methodology specified in HERC MYT Regulations, 2019. Detailed calculation for Inflation factor,
as proposed by Discoms has been tabulated below:-

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CPI & WPI Indices

CPI WPI
Month
FY 2021-22 FY 2022-23 FY 2021-22 FY 2022-23
April 345.9 367.8 132.0 152.3
May 347.3 371.5 132.9 155.0
June 350.5 372.1 133.7 155.4
July 353.7 374.1 135.0 154.0
August 354.2 375.0 136.2 153.2
September 355.1 378.1 137.4 151.9
October 359.7 381.6 140.7 152.9
November 362.0 381.6 143.7 152.5
December 361.2 381.0 143.3 150.5
January 360.3 382.5 143.8 150.7
February 360.0 382.2 145.3 150.9
March 362.9 383.9 148.9 151.0
Average 356.1 377.6 139.4 152.5
Data source: Office of Economic Advisor, Ministry of Commerce & Industry, GoI

Based on above values for indices, inflation factor for ARR period works as follows: -

Inflation Factor for ARR year FY 2024-25

Particulars WPI CPI Total
Weightage 0.45 0.55 1.00
Avg Indexation for FY 2022-23 152.53 377.62
Avg Indexation n (Index * Wt.) 68.64 207.69 276.33
Avg Indexation for FY 2021-22 139.41 356.06
Avg Indexation n-1 (Index * Wt.) 62.73 195.84 258.57
Combined Inflation (Indxn/Indxn-1) 6.87%

The Commission has examined the calculations and approves the same as it is in line with the
HERC MYT Regulations in vogue.

5.9.1 Employee Expenses

UHBVNL
UHBVNL, in its petition, has submitted that the Nigam has planned to scale up its existing IT
infrastructure to strengthen IT backbone for robust distribution network. Capital works are being
undertaken to digitalize the business processes as well as improve the quality of services and
system reliability of the network. Special focus is also kept in standardizing business processes,
minimizing lead time in administrative approval/works, improving consumer satisfaction rate,
implementation of smart metering and digitalization of payment. Thus, to upkeep the Discoms

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with rapid changing technology in distribution sector and to manage the ever-increasing
distribution infrastructure, specialized manpower to the tune of 4489 new employees is to be
recruited by the Discoms in FY 2024-25. The impact on employee cost due to addition of new
employees is incorporated in ARR year by considering basic salary of Rs 25,000 per month for
each employee. Thus, employee expenses for APR year are indexed to estimate corresponding
expense for ARR year and cost of new employees is added to this estimate.

Dearness allowance of 8% is additionally disbursed by the government of Haryana in the APR

year. Hence, the same is indexed for calculation of corresponding expenses for ARR year.

Besides, terminal benefits for FY 2024-25 have been considered Rs 450 Crs, and are kept same
as approved for FY 2023-24 in the Tariff order dated 15.02.2023.

UHBVNL employee expenses for ARR year on the basis of above details is tabulated as follows:

Projected Employee Expenses for FY 2024-25 UHBVNL (Rs. Crore)

Particulars FY 2024-25
Salaries 808.10
Dearness Allowance 337.52
Other Allowances 138.74
Terminal benefits 450.00
Gross Employee Expense 1,734.37
Less Expenses Capitalised 6.86
Net Employee Expenses 1,727.50

DHBVNL
DHBVNL, in its petition, has submitted that the Nigam has planned to scale up its existing
infrastructure for robust distribution network. Capital works are being undertaken to digitalize
the business processes as well as improve the quality of services and system reliability of the
network. Special focus is also kept in standardizing business processes, minimizing lead time in
administrative approval/works, improving consumer satisfaction rate, implementation of smart
metering and digitalization of payment. Thus, to upkeep the Discoms with rapid changing
technology in distribution sector specialized manpower to the tune of 866 are planned to be
recruited in FY 2024-25. Considering the basic salary of Rs. 25,500/- and applicable dearness
allowance, employee cost for these planned new recruitments is included over and above the
employee cost estimation explained in previous point.

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Terminal liability for ARR year is claimed equivalent to actual terminal liability of FY 2022-23.
Summary of employee expenses is tabulated as follows: -

Projected Employee Expenses for FY 2024-25 DHBVNL (Rs Crore)

Particulars FY 2024-25
Salaries 634.97
Dearness Allowance 342.89
Expenditure on Employees Engaged on Contractual Basis 278.33
Other Allowances 110.91
Gross Employee Expense 1367.10
Less: Expenses Capitalized 22.24
Net Employee Expenses 1344.85
Add: Terminal Liability 697.77
Total Employee Expense 2042.62
In view of above, the Discom(s) prayed that the Hon’ble Commission may allow the projected
employee cost for ARR year.

The Commission has examined the projections of employee cost by UHBVNL and DHBVNL for
the FY 2024-25 and observes that the proposed cost on account of employees are higher as
compared to the MYT proposal, recorded in the Commission’s order dated 01.06.2020,
submitted by the licensees. Initially, employee expenses of Rs 1193.35 for UHBVNL and Rs
1486.51 crore for DHBVNL were approved for the FY 2024-25 during the proposal submitted
for the MYT control period for FY 2020-21 to FY 2024-25 vide order dated 01.06.2020.
The Commission, from time to time, observed the increase in such cost and asked the licensee
to look for the deviations. The licensees are again directed to analyze and explain the
aberrations in the MYT projections and that proposed in the present petition i.e. map all the
factors for the increase including number of employees, contractual employees, DA, inflation
factor etc.
However, the Commission has considered the employee cost, including terminal liabilities, for
the FY 2024-25 based on the audited accounts of FY 2022-23, approved true up figures of FY
2022-23 and inflation factor of 6.87% for FY 2023-24 and FY 2024-25.
The methodology, being in line with the Regulations in vogue, as well as the Commission’s
previous order during the MYT control period, approves the employees cost as under:-

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HERC Approved Employee Expenses for FY 2024-25 UHBVNL (Rs. Cr.)

Particulars Projected Approved
Salaries 808.10 808.13
Dearness Allowance 337.52 292.06
Other Allowances 138.74 138.76
Terminal benefits 450.00 450.00
Gross Employee Expense 1,734.37 1688.95
Less Expenses Capitalised 6.86 6.68
Net Employee Expenses 1,727.50 1682.27

HERC Approved Employee Expenses for FY 2024-25 DHBVNL (Rs Crore)

Particulars Projected Approved
Salaries 634.97 635.01
Dearness Allowance 342.89 311.15
Expenditure on Employees Engaged on Contractual Basis 278.33 278.35
Other Allowances 110.91 110.91
Gross Employee Expense 1367.10 1335.42
Less: Expenses Capitalized 22.24 22.33
Net Employee Expenses 1344.85 1313.09
Add: Terminal Liability 697.77 697.77
Total Employee Expense 2042.62 2010.86

Terminal benefits, have been approved, as proposed by the Discoms, and the same will be
subsequently trued-up based on the audited accounts of the FY 2024-25.

5.9.2 Repair & Maintenance (R&M) Expenses

Revised estimate for R&M Expenses is calculated as per Regulation 57.4 of MYT Regulations
2019. Based on Average GFA, K factor (1.65%) and inflation factor calculated in previous section
are considered for revised R&M expenses for APR year is calculated and tabulated as follows:

Projected R&M Expenses for FY 2024-25 UHBVNL (Rs Crore)

Particulars FY 2024-25
Average GFA 10,817.92
K factor 1.65%
Indexation 6.87%
Less: expenses capitalized -
R&M Expenses (Avg. GFA x K x (1+Indexation)) 190.75

Projected R&M Expenses for FY 2024-25 DHBVNL (Rs Crore)

Particulars FY 2024-25
Average GFA for Current Year 14,194.11
K factor 1.65%
Indexation % 6.87%
R&M Expenses 250.29

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The Commission has examined the projections of R&M Expenses submitted by the licensees and
finds the methodology used by the licensees in Order. However, as the Commission approved
average GFA for the FY 2024-25 is lower than that proposed by the Licensees, the R&M has
undergone a slight change. The resultant R&M expenses for the FY 2024-25, as approved by the
Commission, is given in the table below:-

HERC Approved R&M Expenses for FY 2024-25 for UHBVNL (Rs Crore.)
Particulars Proposed HERC Approved
Average GFA 10817.92 10607.87
K factor 1.65% 1.65%
Indexation % 6.87% 6.87%
Less: expenses capitalized - -
R&M Expenses 190.76 187.05

HERC Approved R&M Expenses for FY 2024-25 for DHBVNL (Rs Crore)
Particulars Proposed HERC Approved
Average GFA for Current Year 14,194.11 14110.41
K factor 1.65% 1.65%
Indexation % 6.87% 6.87%
R&M Expenses 250.29 248.82

5.9.3 Administration & General (A&G) Expenses

UHBVNL
The audited Administrative & General (A&G) expenses of the true-up year is adequately indexed
with inflation factor to calculate the estimated A&G expenses for APR year and thereafter for
ARR year.
The Commission has examined the projections of A&G expenses by UHBVNL and DHBVNL for
the FY 2024-25 and observes that the escalation and indexation factors used by the licensees
are in order. Accordingly, the Commission approves the A&G expenses, taking trued up A&G
expenses as the base and not the actual audited figures, and using appropriate inflation factors
for the APR and ARR years. The amount of A&G expenses approved have been tabulated as
follows:
Approved A&G Expenses for ARR year FY 2024-25 UHBVNL (Rs Crore)
Particulars Proposed Approved
Gross A&G Expenses approved 228.34 128.89
Net A&G Expenses 228.34 128.89

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Approved A&G Expenses for ARR year FY 2024-25 DHBVNL (Rs Cr.)
Particulars Proposed Approved
Gross A&G Expenses 183.57 166.49

Net Administrative & General Exp. 183.57 166.49

Summary of O&M Expenses

Approved O&M expenses of UHBVNL and DHBVNL for FY 2024-25 have been tabulated as under:
Approved O&M Expenses for FY 2024-25 UHBVNL (Rs Cr.)

Particulars Proposed Approved FY 2024-25

Employee Expense 1277.5 1,232.27
A&G Expense 228.34 128.89
R&M Expense 190.75 187.05
Terminal Benefits 450 450.00
Total O&M Expenses 2,146.59 1,998.21

Approved O&M Expenses for FY 2024-25 DHBVNL (Rs Cr.)

Particulars Proposed Approved FY 2024-25
Employee Expenses 1344.85 1,313.09
A&G Expenses 183.57 166.49
R&M Expenses 250.29 248.82
Terminal Benefits 697.77 697.77
O&M Expenses (Total) 2476.48 2,426.91
5.10 Approved Capital Expenditure and additions to Gross Fixed Asset
The Commission, after careful examination of the proposed capital expenditure for the
FY 2024-25, has approved Rs. 1036 crores and Rs. 1276 crores as the capital expenditure for
UHBVNL and DHBVNL respectively which is inclusive of deposit works on account of tube well
connections of Rs. 12.50 crores and Rs 159.83 crores respectively. Since the deposit works are
neither included in the final GFA nor are required to be funded through equity or loans, the same
are excluded from the calculations of ARR. The capitalization/ transfer to GFA is in the same ratio
as proposed by the licensees, as per last audited accounts available. The retirement/ disposal of
assets is also in the same ratio as proposed by the respective licensees as part of the MYT
petition, as per last audited accounts available.
The Commission has approved the consumer contribution as proposed by the Discoms, as the
same is in line with the MYT petition. Further, Equity Capital is pegged at 20% of the approved

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capital expenditure for each licensee and the remaining / balance capital expenditure has been
considered to be funded by way of long-term loan in line with the MYT Regulations in vogue.
The calculation of approved capital expenditure, additions to GFA and funding thereto is given
in the following table: -
Approved Capital Expenditure, GFA and Funding for the FY 2024-25 (Rs. Crores)
Capital Work in Progress (CWIP) UHBVNL DHBVNL
Opening CWIP 604.50 1116.96
Addition 1023.50 1116.17
Capex Capitalized 974.68 1104.72
Closing CWIP 653.32 1128.41
Gross Fixed Assets (GFA)
Opening GFA 10357.48 13598.41
Add: Trf from CWIP 974.68 1104.72
Less: Retirement/Disposal of Assets 473.92 80.70
Closing GFA 10858.25 14622.42
Average GFA 10607.87 14110.41
Source of Funding for additions and IDC
Consumer Contribution 12.50 159.83
Equity 204.70 223.23
Debt 806.30 733.11
Total 1023.50 1116.17
5.11 Interest & Finance Charges:
5.11.1 Interest on Long Term Loan
Interest on capex loan for FY 2024-25 ARR has been projected by the Discoms as per Regulation
21 of HERC MYT Regulations 2019. Interest on long-term borrowing has been computed loan-
wise as per the applicable interest rate. The relevant excerpt of the HERC MYT Regulations, 2019
is reproduced as under:

“Regulation 21.1 Existing Loans

(i) Interest on loan capital shall be computed loan-wise for existing loans arrived in a manner
specified in Regulation 19 and shall be as per the rates approved by the Commission.

(ii) The loan outstanding as on 1st April of each financial year shall be worked out as the gross
loan in accordance with Regulation 19 by deducting the cumulative repayment as admitted by
the Commission up to 31st March of previous financial year from the gross normative loan;

(iii) The rate of interest shall be the weighted average rate of interest on institutional loans
calculated on the basis of the actual loan portfolio at the beginning of each year applicable to the

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project. In case the weighted average rate is not available, the interest rate approved by the
Commission in its earlier tariff order shall be allowed

Provided that if there is no actual loan for a particular year but normative loan is still outstanding,
the last available weighted average rate of interest shall be considered;

Provided further that if the generating plant/project does not have actual loan, then the weighted
average rate of interest of the generating company/licensee as a whole shall be considered.

(iv) The interest on loan shall be calculated on the normative average loan of the year by
applying the weighted average rate of interest;

(v) The generating company and the licensee shall from time to time review their capital
structure i.e. debt and equity and make every effort to restructure the loan portfolio as long as it
results in net savings on interest. The costs associated with such re-financing shall be borne by
the beneficiaries and the net savings (after deducting the cost of re-financing) shall be subjected
to incentive / penalty framework as mentioned in the Regulation 12 which shall be dealt with at
the time of mid-year performance review/true-up

(vi) The changes to the loan terms and conditions shall be reflected from the date of such re-
financing and benefit passed on to the beneficiaries;

(vii) In case of any dispute relating to re-financing of loan, any of the parties may approach
the Commission with proper application along with all the relevant details. During the pendency
of any dispute, the beneficiaries shall not withhold any payment on account of orders issued by
the Commission.

Regulation 21.2 New Loans (on or after 6th April 2019)

(i) Rate of interest on new loans i.e. on or after 01.04.2020 shall be equal to the marginal
cost of funds-based lending rate (MCLR) of the SBI plus a maximum of 150 basis points w.r.t.1st
April of the relevant financial year. They shall however, be required to submit due justification to
the Commission for the terms and conditions of the loans raised by them including the loan
sanction letter from the banks/ lending institutions, indicating the applicable rate of interest.

Provided that interest and finance charges on works in progress shall be excluded and shall be
considered as part of the capital cost;

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HERC ORDER ON TRUE-UP FOR THE FY 2022-23, ANNUAL (MID-YEAR) PERFORMANCE REVIEW FOR THE FY 2023-24, AGGREGATE REVENUE
REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Provided further that neither penal interest nor overdue interest shall be allowed for computation
of Tariff

(ii) Any variation above or below the allowed interest rate shall be subject to the incentive
and penalty framework specified in Regulation 12. The incentives on refinancing should be net of
costs.

(iii) The amount of loan shall be arrived in the manner as specified in Regulation 19 and shall
be based on the approved capital investment plan.

(iv) In case any moratorium period on repayment of loan is availed of by the generating
company or the licensee, depreciation provided for in the tariff during the years of moratorium
shall be treated as repayment during those years and interest on loan capital shall be calculated
accordingly.”

Term loans are largely funded from REC, nationalized banks and scheduled commercial banks.
The new receipts in term loans are considered to be funded from REC only. Thus, the financing
cost of new receipts during the ARR years is calculated based on the average interest rate of
existing REC loans.

Repayment of term loan is considered equivalent to the depreciation claimed during the ARR
year.

UHBVNL:

UHBVNL, in its petition, has submitted that Interest on CAPEX loans has been projected for the
ARR year FY 2024-25 in accordance with the estimated receipt of Capex loans with repayment
considered equivalent to depreciation claimed for the current year. Furthermore, the debt
component of the capital expenditure has also been considered primarily from REC. The
projected interest on CAPEX loan by UHBVNL is Rs 173.44 Cr for FY 2024-25.

DHBVNL
DHBVNL, in its petition, has submitted that the Long-term borrowings for Capital Expenditure
Plan for ARR year FY 2024-25 is mainly from REC Ltd. & Commercial banks.

The projected CAPEX Loan profile for the ARR year i.e. FY 2024-25 for DHBVNL is summarized in
the table below: -

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Projected CAPEX loan Profile for FY 2024-25 DHBVNL (Rs Crore)

Opening Closing Interest cost
Interest rate Total Total
Name of Lender Balance as on Balance as on during the
(in %) Receipt Repayment
01.04.2024 31.03.2025 year
PMGY (GOH ) 10.50-12.00 0.03 0.00 0.03 0.00 0.00
APDRP (GOH) 10.50-12.50 0.00 0.00 0.00 0.00 0.00
REC (Term Loan) 8.21-10.85 1264.58 0.00 353.63 910.94 137.34
WB Loan LIBOR+Spread 190.32 0.00 12.46 177.86 2.62
JICA Loan 0.8% 3.00 0.00 0.00 3.00 0.00
Central Bank of India 7.45% 352.20 0.00 63.72 288.48 36.71
State Bank of India
8.75% 453.95 0.00 26.32 427.63 38.79
TL-II
Indian Bank 8.45% 542.05 0.00 41.38 500.67 44.05
PFC Ltd. 9.00% 751.82 0.00 47.62 704.20 69.86
Fis/Banks/RDSS
8.50% 0.00 1032.14 0.00 1032.14 48.88
Counterpart funding
Total (A) 3557.94 1032.14 545.15 4044.92 378.25

Based on above, DHBVNL has projected interest on loan for the ARR year FY 2024-25 as under:

Projected Interest on CAPEX loan for FY 2024-25 DHBVNL (Rs Crore)

Particulars FY 2024-25
Gross Interest on CAPEX loans 378.25
Less: Interest Capitalized 181.06
Net Interest on CAPEX loans 197.19

The Commission has carefully considered the calculations of interest on long term loans
proposed by the Discoms and agrees with the methodology where the additions to borrowings
are in accordance with the funding of proposed capital expenditure and the repayment is equal
to the depreciation for the year. However, since the approved capital expenditure and its
funding is at variance with that proposed by the licensee, it has resulted in some variance in
the interest cost on term loans as well as return on equity. The Commission has limited the
consumer contribution in proportion to the amount proposed by the respective Discoms for
the FY 2024-25 and Equity is kept at 20% of the approved capital expenditure. In accordance
with the MYT regulations 2019, interest on loans is calculated at the weighted average rate of
interest on existing institutional loans as submitted by the licensees i.e. 7.28% for UHBVNL and
8.36% for DHBVNL. The capitalization of assets has been considered at the same level as of the
audited accounts for the FY 2022-23.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

HERC approved Interest on capex loans UHBVNL FY 2024-25 (Rs Crores)

Particulars Proposed Approved
Opening Balance 2578.92 2578.92
Projected addition during the year 859.64 806.30
Repayments of Loan 453.94 415.97
Closing Balance 2984.62 2969.25
Average balance during the Year 2,781.77 2,774.08
Interest Rate (%) 8.31% 7.28%
Interest Payment 231.27 201.95
Less: Interest Capitalized 57.83 43.62
Net Int. on Capex Loans 173.44 158.33

HERC approved Interest on capex loans DHBVNL FY 2024-25 (Rs Crores)

Particulars Proposed Approved 2024-25
Opening Balance 3,557.94 3557.94
Deemed Addition during the year 1032.14 733.11
Repayments of Loan 545.15 416.53
Closing Balance of Deemed Loan 4,044.93 3874.52
Average balance during the Year 3,801.44 3,716.23
Interest Rate (%) 9.95% 8.36%
Interest Payment 378.25 310.68
Less: Interest Capitalized 181.06 148.71
Net Int. on Capex Loans 197.19 161.96
5.11.2 Interest on Advance Consumption Deposit (ACD)
Interest on consumer security deposits for ARR year is calculated in accordance with Regulation
21.4 of MYT Regulations, 2019.

The relevant excerpt of the regulation is reproduced as under:

"Interest shall be allowed on the amount held as security deposit held in cash from Transmission
System Users, Distribution System Users and Retail consumers, at the Bank Rate as on 1st April
of the financial year in which the petition is filed provided it is payable by the
transmission/distribution licensee.”

UHBVNL
UHBVNL, in its petition, has submitted that receipt of consumer security deposit for ARR year
has been calculated by considering the consumer security deposit during the true up year i.e. FY
2022-23 and increase in number of consumers on Year to Year (YoY) basis. Estimated cost of
interest on consumer security deposit projected by UHBVNL is tabulated as follows:

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Projected Interest on Consumer Deposit for FY 2024-25 UHBVNL (Rs Crore)

Particulars FY 2024-25
Opening balance 1,759.44
Receipt during the year 190.25
Closing balance 1,949.69
Average security deposit 1,854.56
RBI Bank Rate 6.75%
Interest on Consumer Security Deposit 125.18

UHBVNL has prayed that the Hon’ble Commission may allow the estimated interest cost on
consumer security deposit for ARR year.
DHBVNL
DHBVNL, in the present petition, has submitted that as per the bank rate notified by RBI for
01.04.2023, interest on consumer security deposit is calculated at 6.75%.

Receipt of consumer security deposit for ARR year FY 2024-25 has been projected by escalating
the receipt of consumer security deposit during previous year with the load growth of the
relevant years. Details of interest on consumer security deposit is tabulated as under:

Projected Interest on Consumer Security deposit for FY 2024-25 DHBVNL (Rs. Crore)
Description FY 2024-25
Opening balance 2823.34
Receipt during the year 242.92
Closing balance 3066.26
Average Security deposit 2944.80
Interest rate 6.75%
Interest on Consumer Security Deposit 198.77
DHBVNL has prayed that the Commission may allow the interest cost on consumer security
deposit for FY 2024-25 as computed in above.

The Commission has examined the calculations of interest on consumer security deposit for
the FY 2024-25 as proposed by the Discoms and approves the same.

5.11.3 Interest on Working Capital Loan

UHBVNL
UHBVNL, in its petition, has submitted that interest on working capital loans has been projected
at Rs. 130.87 Cr based on normative values as per HERC MYT Regulation.
Revenue gap during the ARR year, if any, is planned to be met from deficit financing (borrowings).
DHBVNL

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL, in its petition, has submitted that as per Regulation 22.2 of HERC MYT Regulations,
2019, interest on working capital for FY 2024-25 is computed on normative basis. Rate of interest
on working capital is considered as 10% (SBI 1 Yr. MCLR of 8.50% as on 01.04.2023 plus 150 basis
points).

Normative Interest on working capital for FY 2024-25 (Rs. Crore)

Sr. No. Category FY 2024-25
1 Receivables of two months 4012.79
2 O&M Expense of 1 Month 206.37
3 Maintenance Spares for 1 Month 11.34
4 Uncollected Revenue 120.38
5 Less: Consumer Security Deposit 2823.34
6 Total Working Capital Requirement 1527.54
7 Normative interest rate on Working Capital 10.00%
8 Interest on Working Capital 152.75
The Commission has examined the interest on working capital borrowings as projected by the
licensee and observes that the procedure is in accordance with the MYT Regulations, 2019, which
provides for a specific methodology for calculation of interest on working capital borrowings for
the Distribution and retail supply business as given below:

“22. INTEREST ON WORKING CAPITAL

22.1 Components of working capital:
Distribution licensee
I. Wheeling of electricity:
a) Normative O&M expenses for wheeling business for 1 (one) month;
b) Maintenance spares for 1 (one) month based on annual requirement considered at 1% of GFA
(wire business) at the end of the previous year;
c) Receivables equivalent to 2(two) month of wheeling charges.
less
Amount held as security deposits in cash from Distribution System Users :
Provided further that for the purpose of Truing-up for any year, the working capital requirement
shall be re-computed on the basis of the values of components of working capital approved by
the Commission in the Truing-up before sharing of gains and losses
II. Retail supply of electricity:
a) Normative O&M expenses for retail supply business for 1 (one) month;
b) Maintenance spares for 1 (one) month based on annual requirement considered at 1% of the
GFA at the end of the previous year;
c) Uncollected revenue to be calculated as: Revenue billed for the relevant year * (1 – Normative
Collection efficiency)

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

d) Receivables equivalent to 2 (two) months’ of billing less consumers’ security / advance

consumption deposit.
Provided that for the purpose of Truing-up for any year, the working capital requirement shall be
re-computed on the basis of the values of components of working capital approved by the
Commission in the Truing-up before sharing of gains and losses;
22.2 Rate of Interest
Rate of interest on working capital shall be equal to the MCLR of the relevant financial year plus
a maximum of 150 basis points. However, while claiming any spread, the generator and the
licensees shall submit loan sanction letter from the banks/ lending institutions, indicating the
applicable rate of interest.”
The Commission has estimated working capital requirement in accordance with the MYT
Regulations and the rate of interest i.e. MCLR plus a margin of 150 basis points (1.50%) or
actual rate of interest on working capital, whichever is lower. Thus, the Commission approves
the rate of interest on working capital borrowings, as per actual, i.e. 7.41% PA, as against the
normative rate of 10% P.A proposed by the licensee.
In the case of DHBVNL, the Commission observes that the actual rate of interest on working
capital for the FY 2022-23 is 6.49% P.A as against the normative rate of 10% P.A, as proposed
by the Nigam. Therefore, the rate of interest on working capital is allowed as per actual i.e.
6.49% P.A.
Approved Interest on working capital UHBVNL FY 2024-25 (Rs Crore)

Interest on working capital Approved FY 2024-25

O&M expenses for 1 month 166.52
Maintenance spares 1% of opening GFA 103.57
2 months receivables 3103.49
Uncollected revenue 93.10
Total 3466.68
Less
ACD, as projected by UHBVNL 1759.44
Net working capital 1707.24
Interest rate 7.41%
Interest cost 126.51
Approved Interest on working capital DHBVNL FY 2024-25 (Rs in crore)
Interest on working capital Approved FY 2024-25
O&M expenses for 1 month 202.18
Maintenance spares 1% of opening GFA 115.18
2 months receivables 4325.16
Uncollected revenue 129.75
Total 4772.27

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Less
ACD 2823.34
Net working capital 1948.93
Interest rate 6.49%
Interest cost 126.49

Summary of Net Interest & Finance charges for FY 2024-25

UHBVNL
UHBVNL, in its petition, has submitted that other Finance Charges for ARR year are considered
as Rs 34.90 Cr, kept same as approved in the Tariff order for FY 2023-24.

Proposed Net Interest & Finance Charges for FY 2024-25 UHBVNL (Rs Cr.)
Particulars FY 2024-25
Gross Int. on Capex loans 231.27
Less: Interest Capitalized 57.83
Net Int. on Capex Loans 173.44
Interest on WC loans 130.87
Interest on Security Deposits 125.18
Other Interest and Finance Charges 34.90
Net Interest & finance charges 464.39
UHBVNL prayed that the total estimated interest cost for ARR year, as above, may be allowed by
the Commission.

DHBVNL
DHBVNL has submitted that in addition to the working capital interest expenses, other interest
and finance charges and guarantee fee to the State Government on account of payment of
guarantee fee for new loans have also been considered in the ARR.
The summary of net Interest & Finance charges for FY 2024-25 of DHBVNL is as under:

DHBVNL Projected Net Interest & Finance Charges for FY 2024-25 (Rs. Crore)
Particulars FY 2024-25
Gross Int. on Capex loans 378.25
Less: Interest Capitalized 181.06
Net interest on Long Term CAPEX loans 197.19
Interest on WC loans 152.75
Interest Cost on Consumer Security Deposit 198.77
Guarantee Fee 50.00
Other Interest & Finance Charges (including LC to Power Generators charges) 25.01
Net Interest & Finance Charges 623.73
DHBVNL has prayed that the above projected interest cost for ARR year FY 2024-25 may be
allowed by the Commission in the ARR of the relevant year.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The Discoms have also proposed to recover certain other finance charges, guarantee fee, etc.
and the same are allowed as proposed, subject to true up. In light of the above discussion, the
Commission approves interest cost of UHBVNL and DHBVNL for the FY 2024-25 as under: -

HERC approved Total Interest Cost FY 2024-25 UHBVNL (Rs. Crores)

Particulars Proposed Approved FY 2024-25
Gross Int. on Capex loans 231.27 201.95
Less: Interest Capitalized 57.83 43.62
Net Int. on Capex Loans 173.44 158.33
Interest on WC loans 130.87 126.51
Interest on Security Deposits 125.18 125.18
Guarantee Fees/Other Interest and Finance Charges 34.90 34.90
Net Interest & finance charges 464.39 444.92

HERC approved Total Interest Cost FY 2024-25 DHBVNL (Rs. Crores)

Particulars FY 2024-25 Proposed Approved
Gross Int. on Capex loans 378.25 310.68
Less: Interest Capitalized 181.06 148.71
Net interest on Long Term CAPEX loans 197.19 161.96
Interest on WC loans 152.75 126.49
Interest Cost on Consumer Security Deposit 198.77 198.774
Guarantee Fee 50 50
Other Interest & Finance Charges (including LC to Power 25.01 25.01
Generators charges)
Total interest cost 623.72 562.23

5.12 Depreciation
Depreciation for ARR year is to be considered in accordance with Regulation 23 of the HERC MYT
Regulations, 2019. The relevant excerpt is reproduced as under: -

"….(a)The value base of asset shall be the historical capital cost of the asset as admitted
by the Commission. The historical capital cost shall include additional capitalization
including foreign exchange rate variation, if any already allowed by the Commission up
to 31st March of the relevant year.

(b)The residual value of the asset shall be considered as 10% and depreciation shall be
allowed up to maximum of 90% of historical capital cost of the asset;

Provided that the salvage value for IT equipment and software shall be considered as
NIL and 100% value of the assets shall be considered depreciable.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

(c)Depreciation shall be calculated annually over the useful life of the asset at the rates
specified in Appendix II up to 31st March of the 12th year from the date of commercial
operation of the asset. From 1st April of 13th year from the commercial date of
operation of the asset, the remaining depreciable value if any out of the 90% of the
capital cost of the asset shall be equally spread over the balance useful life of the asset.

The deprecation rates given in Appendix-II will be applicable w.e.f. 1.04.2020 only. The
depreciation, in case of existing assets, up to 31.03.2020 shall be considered as already
allowed and shall not be re- visited. The deprecation rates as per Appendix-II for such
assets shall be applicable w.e.f 1.04.2020 up to 12th year from the date of COD.

Provided that the rate provided in Appendix II, are the upper ceiling of the rate of
depreciation to be provided up to 12th year from the date of COD and the developer
shall have the option of indicating, while seeking approval for tariff, lower rate of
depreciation, subject to the aforesaid ceiling.

(d)Land shall not be considered as a depreciable asset and cost shall be excluded from
the capital cost while computing depreciable value of asset.

(e)Depreciation shall be chargeable from the first year of commercial operation. In case
of commercial operation of the asset for part of the financial year, then the
depreciation shall be charged on pro rata basis;

(f)Depreciation shall not be allowed on assets (or part of assets) funded by consumer
contribution (i.e., any receipts from consumers that are not treated as revenue) and
capital subsidies / grants. Provision for replacement of such assets shall be made in the
capital investment plan."

Depreciation amount for the ARR year i.e. FY 2024-25 has been projected as per asset class wise
depreciation rates on Opening GFA of respective year. Depreciation on assets funded by
consumer contribution is adjusted further to estimate the depreciation expense for ARR year FY
2024-25.

Detail of depreciation as proposed by the licensees for FY 2024-25 is provided in the table
below: -

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Proposed Depreciation for FY 2024-25 UHBVNL (Rs Crore.)

Opening Rate of Closing
Opening
Particulars Accumulated dep. Depreciation Withdrawals accumulated
GFA
depreciation (%) depreciation
Land & Land Rights 61.74 - - - -
Buildings & Civil
581.11 166.96 3.34% 19.41 0.02 186.35
Structure
Plant & Machinery 9,641.07 3,692.74 5.28% 509.05 163.71 4,038.08
Vehicles 32.33 14.82 9.50% 3.07 0.16 17.73
Furniture & Fixture 137.25 65.61 6.33% 8.69 0.46 73.84
Software 17.27 13.11 15.00% 2.59 - 15.70
Less: Depreciation
on assets
contributed by 88.87 - 263.54
174.67
Consumers and
grants
Total 10,470.77 3,778.57 453.94 164.35 4,068.16
UHBVNL has prayed that the Hon’ble Commission may allow the estimated depreciation of Rs.
453.94 Cr for ARR year.

Proposed Depreciation for FY 2024-25 DHBVNL (Rs. Crore)

Accumulated
Accumulated
Average Depreciation Depreciation
Particulars Rate (%) Depreciation as
GFA as on during the year
on 31.03.2025
31.03.2024
Land 33.03 0.00 0.00% 0.00 0.00
Building & Civil
Structures 467.16 123.64 3.34% 15.60 139.24
Plant & Machinery 13570.85 5233.88 5.28% 716.54 5950.42
Vehicles 34.32 18.72 9.50% 3.26 21.98
Furniture & Fixtures
(Including Office
Equipments) 32.06 18.88 6.33% 2.03 20.91
Intangible Asset 27.99 13.06 15.00% 4.20 17.26
Total 14165.41 5408.17 5.24% 741.63 6149.80
Less: Dep. on assets
from Consumer
Contribution 196.48
Grand Total 545.15
DHBVNL has prayed to the Commission to allow projected depreciation cost of Rs 545.15 crore
for FY 2024-25 as computed in table above.

The Commission has examined the calculations of depreciation for the MYT period submitted
by the Discoms and observes that the Discoms have assumed that the additions to different
class of assets in the MYT period would be in the same ratio as additions in the FY 2022-23. The

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Commission, however, observes that the additions to individual class of fixed assets in a
particular year may not be fully representative of the total requirement of assets for the
Discoms and therefore it would be more appropriate to use total fixed assets as on 31.3.2023
as a composite base and accordingly has assumed that the additions to fixed assets and
consequently the depreciation in the MYT period would also be in the same ratio. The
depreciation calculations for the FY 2022-23 are used to arrive at a composite depreciation rate
which is applied on the opening GFA of each year of the MYT period going forward to arrive at
estimated depreciation for the year. Based on the approved capital expenditure for the FY
2024-25, the approved depreciation for each year of the MYT period is given in table below:

HERC Approved Depreciation FY 2024-25 UHBVNL (Rs. Crore)

Particulars Amount
Opening GFA 10357.48
Rate of Depreciation 4.87%
Total Depreciation 504.63
Less: Depreciation on assets contributed by Consumers and grants 88.66
Approved Depreciation cost 415.97
HERC Approved Depreciation 2024-25 DHBVNL (Rs. Crore)
Particulars Amount
Opening GFA 13598.41
Rate of Depreciation 4.37%
Total Depreciation 594.07
Less: Depreciation on assets contributed by Consumers and grants 177.54
Approved Depreciation cost 416.53

5.13 Return on Equity

Discoms, in their petition, have submitted that the Return on Equity for ARR year has been
projected in accordance with the Regulation 20 of MYT Regulations 2019. The relevant excerpt
of the MYT Regulations is reproduced as follows:

“20. RETURN ON EQUITY

20.1. RoE for generation transmission and distribution, shall be allowed, after adding a premium
over the ’Base Rate (BR)’ based on the performance (both financial as well as operational
parameters) of the power utilities, subject to a cap as under: -
a) Hydro Generators: BR + 6.5% = up to 13 %
Provided that the HEP with pondage or pump storage (PSP) will be eligible for an additional 1%
RoE.
b) Generators other than Hydro: BR + 5.5% = up to 12%
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c) Distribution Business: BR +7.5% = up to 14%

d) Transmission Business: BR + 4.5% = up to 11%.

Provided that the Base Rate (BR) in these Regulations shall be construed as last 2 years average
rate (as on 1st April of the relevant financial year) of 10 years Government of India bond.

Provided, that the RoE for generation, transmission and distribution businesses, shall be allowed,
after adding a premium over the ’Base Rate (BR)’ .

Provided further that RoE shall not exceed 14% in any case. SLDC business shall not be eligible for
RoE.

Provided where the tariff is determined for the entire useful life of the project the RoE allowed
shall not be normally re-visited during the entire tariff period. Hence, the same shall be
determined at 13% with additional 1% for HEPs with pondage or pump storage (PSP) and 12% for
generators other than HEPs.”
UHBVNL

The 10-year GoI bond rate for 1st April 2023 was 7.32% and on 1st April 2022 was 6.86%. The
average of the same is 7.09%. The ROE % calculated in accordance with the 2nd amendment of
HERC MYT Regulations 2019 is greater than 14%. However, considering ROE % approved by the
Hon’ble Commission for FY 2023-24 is @12%, same is considered for estimation of Return of
Equity (in Crs) for ARR year (FY 2024-25).

Based on the eligible equity towards accumulated assets, asset addition during the year and 12%
rate of return, and average equity during the year, the RoE for the ARR year is estimated. Detailed
calculation of RoE, as proposed by UHBVNL, is tabulated below:

UHBVNL proposed Return on Equity for ARR year (Rs Crore)

Particulars FY 2024-25
Net Opening Share Capital 2,631.34
Add: Equity for Capex 214.91
Closing Equity 2,846.25
Average Equity for RoE 2,738.79
Rate of Return on Equity 12.00%
Total Return on Equity 328.66

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

UHBVNL has prayed that the Hon’ble Commission may allow the estimated Return on Equity for
ARR year, as proposed.

DHBVNL

Return on Equity for ARR year FY 2024-25 has been projected in accordance with the Regulation
20 of HERC MYT Regulations, 2019 and its subsequent amendments.

Return on equity is projected at the rate of 12% on the average equity during ARR year FY 2024-
25. Detailed calculation of Return on Equity for ARR year FY 2024-25 is Tabulated as under:

DHBVNL proposed Return on Equity for FY 2024-25 (Rs. Crore)

Particulars FY 2024-25
Opening Equity eligible for Return on Equity 2341.85
Add: Equity addition in capitalization 181.18
Closing Equity 2523.03
Average Equity 2432.44
Rate of Return on Equity 12.00%
Return on Equity 291.89
The licensee has prayed that the projected Return on Equity for the FY 2024-25 may be allowed
as computed in the table above.

The Commission has considered the submissions of the licensees and observes that as per the
MYT Regulations, 2019, ROE can be allowed on the eligible Equity Capital in use. The
Commission, in the light of present petition, approves the rate of Return on Equity at 12% of
average equity utilized in licensed business during the FY 2024-25 to the Discoms.

The calculation of approved return on equity of UHBVNL considering the approved capital
expenditure and its funding thereto and the estimated retirement of assets, is given in the
following table:

Approved Return on Equity for FY 2024-25 UHBVNL (Rs. Crore)

Particulars Proposed Approved
Opening Share Capital eligible for RoE 2,631.34 2,578.41
Less: Equity in Opening CWIP (20%) 0 0.00
Net Opening Share Capital 2,631.34 2,578.41
Add: Equity for Capex 214.91 204.70
Closing Equity 2,846.25 2,783.11
Average Equity for RoE 2,738.80 2,680.76
Rate of Return on Equity 12.00% 12.00%
Total Return on Equity 328.6554 321.691

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

The Commission approves the RoE as proposed by DHBVNL i.e. Rs 291.89 crore, as the
normative RoE is slightly higher than the proposed RoE.

5.14 Bad and Doubtful Debts

DHBVNL, in the present petition, had submitted that provision for Bad and Doubtful debts of Rs.
100.55 Crore for ARR year FY 2024-25 is projected in accordance with Regulation 64 of HERC MYT
Regulations, 2019. The relevant extract of HERC MYT Regulations, 2019 is reproduced as under:

"64 BAD AND DOUBTFUL DEBTS

Bad and doubtful debts shall be allowed to the extent the distribution licensee has actually
written off bad debts subject to a maximum of 0.5% of sales revenue. However, this shall be
allowed only if the distribution licensee submits all relevant data and information to the
satisfaction of the Commission. In case there is any recovery of bad debts already written off, the
recovered bad debts will be treated as other income."

In view of above, Nigam has prayed to approve the provision for bad and doubtful debts as
claimed above.

The Commission is of the view that bad and doubtful debts shall be allowed during true up
only and to the extent the distribution licensee has actually written off bad debts subject to a
maximum of 0.5% of sales revenue i.e. within the four corners of the HERC MYT Regulations in
vogue. Further, during true up, complete details of the bad and doubtful debts need to be
submitted in the petition, as per the MYT regulations in vogue.

5.15 Non-Tariff Income

UHBVNL
Non-Tariff Income for ARR year has been kept same, i.e., Rs. 278.43 Cr, as approved by the
Hon’ble commission for FY 2023-24.

It is requested that the same may kindly be allowed by the Hon’ble Commission for ARR year.

DHBVNL
Non-Tariff Income for FY 2024-25 is proposed as Rs. 308.61 Crore at the same level as claimed in
APR of FY 2023-24.

The Commission finds the proposed amounts of Non-Tariff Income reasonable, and approves
the same.
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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

5.16 Aggregate Revenue Requirement (ARR)

UHBVNL
The revised estimate of Aggregate Revenue Requirement for ARR year, as proposed by UHBVNL,
is tabulated as follows:
UHBVNL Proposed Aggregate Revenue Requirement (Rs Crore)
Sr. No Particulars FY 2024-25
1 Total Power Purchase Expense 14,218.48
1.1 Power Purchase Expense 12,293.34
1.2 Interstate transmission Charge 957.72
1.3 Intrastate transmission & SLDC 967.42
2 Operations and Maintenance Expense 2,146.60
2.1 Employee Expense 1,277.50
2.2 Administration & General Exp. 228.34
2.3 Repair & Maintenance Expense 190.75
2.4 Terminal Liability 450.00
3 Depreciation 453.94
4 Total Interest & Finance Charges 464.39
4.1 Interest on CAPEX loans 173.44
4.2 Interest on Working Capital incl. CC 130.87
4.3 Interest on Consumer Security Deposit 125.18
4.4 Other Interest and Finance charges 34.90
5 Return on Equity Capital 328.66
6 Total Expenditure 17,612.06
7 Less: Non-Tariff Income 278.43
8 Net Aggregate Revenue Requirement 17,333.63
DHBVNL
The revised estimate of Aggregate Revenue Requirement of DHBVNL for FY 2024-25 is tabulated
as under:
DHBVNL Proposed Aggregate Revenue Requirement (Rs. Crore).
ARR
S. No. Particulars FY 2024-25
Projected
1.0 Power Purchase Expenses 20,347.52
1.1 Power Purchase Cost 17,581.01
1.2 Transmission Charges 1,382.07
1.3 Transmission Charges & SLDC 1,384.44
2.0 Operation & Maintenance Expenses 2,476.48
2.1 Employee Expenses (net) 1,344.85
2.2 Administration & General Expenses (net) 183.57
2.3 Repair & Maintenance Expenses 250.29
2.4 Terminal Benefits 697.77
3.0 Depreciation 545.15
4.0 Interest & Finance Charges 623.73
4.1 Interest on Long Term Loan 197.19
4.2 Interest on Working Capital 152.75

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ARR
S. No. Particulars FY 2024-25
Projected
4.3 Interest on Consumer Security Deposit 198.77
4.4 Other Interest & Finance Charges 25.01
4.5 Guarantee Fee 50.00
5 Return on Equity Capital 291.89
6 Provision for Bad & Doubtful Debt 100.55
7 Aggregate Revenue Requirement 24,385.33
8 Less: Non-Tariff Income 308.61
9 Net Aggregate Revenue Requirement 24,076.71

Based on the Commission’s approved estimates of various components of the ARR, as

discussed in the previous paragraphs, the approved Revenue Requirement (in Rs. Crores) for
the FY 2024-25 for the two Discoms is as under:-
UHBVNL Aggregate Revenue Requirement for ARR year FY 2024-25 (Rs Crore)
Sr. No Particulars Proposed Approved
1 Total Power Purchase Expense 14,218.48 15,718.54
1.1 Power Purchase Expense 12,293.34 13,826.58
1.2 Interstate transmission Charge 957.72 957.72
1.3 Intrastate transmission & SLDC 967.42 934.24
2 Operations and Maintenance Expense 2,146.59 1,998.21
2.1 Employee Expense 1,277.50 1,232.27
2.2 Administration & General Exp. 228.34 128.89
2.3 Repair & Maintenance Expense 190.75 187.05
2.4 Terminal Liability 450 450
3 Depreciation 453.94 415.97
4 Total Interest & Finance Charges 464.39 444.92
4.1 Interest on CAPEX loans 173.44 158.33
4.2 Interest on Working Capital incl. CC 130.87 126.51
4.3 Interest on Consumer Security Deposit 125.18 125.18
4.4 Other Interest and Finance charges 34.9 34.9
5 Return on Equity Capital 328.66 321.69
6 Total Expenditure 17,612.06 18,899.34
7 Less: Non-Tariff Income 278.43 278.43
8 Net Aggregate Revenue Requirement 17,333.63 18,620.91

DHBVNL Aggregate Revenue Requirement for ARR year FY 2024-25 (Rs Crore)
No Particulars Proposed Approved
1 Power Purchase Expenses 20,347.52 22,254.16
1.1 Power Purchase Cost 17,581.01 19,786.69

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

No Particulars Proposed Approved

1.2 Inter State Transmission Charges 1,382.07 1,382.07
1.3 Intra State Transmission Charges & SLDC 1,384.44 1,085.40
2 Operation & Maintenance Expenses 2,476.48 2,426.16
2.1 Employee Expenses (net) 1,344.85 1,313.09
2.2 Administration & General Expenses (net) 183.57 166.49
2.3 Repair & Maintenance Expenses 250.29 248.82
2.4 Terminal Benefits 697.77 697.77
3 Depreciation 545.15 416.53
4 Interest & Finance Charges 623.72 562.23
4.1 Interest on Long Term Loan 197.19 161.96
4.2 Interest on Working Capital 152.75 126.49
4.3 Interest on Consumer Security Deposit 198.77 198.774
4.4 Other Interest & Finance Charges 25.01 25.01
4.5 Guarantee Fee 50 50
5 Return on Equity Capital 291.89 291.89
6 Provision for Bad & Doubtful Debt 100.55 0
7 Aggregate Revenue Requirement 24,284.76 25,950.97
8 Less: Non-Tariff Income 308.61 308.61
9 Net Aggregate Revenue Requirement 23,976.15 25,642.36

5.17 Revenue Estimation

UHBVNL
UHBVNL, has submitted that due to non-availability of requisite data for revenue assessment of
new consumer categories, revenue from sale of power for ARR year is estimated based on the
previous consumer categories and re-categorized thereafter accordingly.
In accordance with the category-wise energy sales projected for ARR year and applicable retail
supply tariff approved in Tariff Order dated 15.02.2023, revenue from sale of power is estimated
for ARR year and the same is tabulated as follows:
UHBVNL proposed Revenue from Sale of Power for FY 2024-25 (Rs Crore)
Sr. No. Category Proposed
1 Domestic Supply 3,901.47
2 HT Supply 7,029.48
3 LT Supply 2,043.66
5 Agriculture 53.96
6 PWW/Lift Irrigation/MITC/Street Light 659.28
7 Bulk Supply 284.24
9 Total 13,972.10
10 Collection Efficiency 99.50%
11 Revenue Realised 13,902.23

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL:
DHBVNL, has submitted that Revenue from sale of power is determined on basis of the projected
sales and current level of retail supply tariff. Category wise revenue from sale of power for FY
2024-25 is given in table below:
DHBVNL proposed Revenue from Sale of Power for FY 2024-25 (Rs Crore)
Sr.no. Category Projected Amount
1 Domestic Supply 4,864.59
2 HT Supply 10,486.58
3 LT Supply 2,542.85
4 Agro Industry/FPO 9.11
5 Agriculture 66.09
6 Bulk Supply 1162.78
7 Public Water Works 977.35
8 Total 20,109.35

DHBVNL submitted that Revenue from inter-state sales is estimated on the basis of average
variable power purchase cost and surplus power available during the year. However, it is
observed that the Discoms have not proposed to garner revenue from inter-state sale of power
for the FY 2024-25 on the basis of data shared by the petitioner(s) in their petition. The
Commission is of the considered view that in case the Merit Order Dispatch principle is strictly
followed and the energy which is surplus is contracted to be sold at its variable cost/ ECR, the
revenue generated would be higher than the average variable power purchase cost and would
ultimately go towards reducing the power purchase cost. The Commission, instead of calculating
revenue from interstate sale separately as a line item in the ARR, has preferred to calculate the
power purchase cost only for the energy required for sale to the electricity consumers of
Haryana. i.e. fixed cost for long term PPA’s is considered to be pass through and the projected
power purchase volume is allowed at the average variable cost.

5.18 AP Tubewell Subsidy

UHBVNL and DHBVNL, have submitted that Agriculture Subsidy for the FY 2024-25 is considered
same as allowed by the Hon’ble Commission for FY 2023-24 in Tariff Order dated 15.02.2023 and
therefore, the Agriculture Subsidy for ARR year has been projected as Rs. 2884.97 Cr for each
Discom.
The Commission observes that the Discoms have projected Agriculture Subsidy for the FY 2024-
25 equivalent to the subsidy allowed for the FY 2023-24 in Tariff Order dated 15.02.2023 and

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also that there is no projection for estimated subsidy for power supplied to either the domestic
consumers, MSME or for that matter any other consumer category. In line with the provisions of
section 65 of the Electricity Act, there has to be commitment from State Government and the
payment of subsidy has to be made in advance. The relevant section is reproduced as under:-

“Section 65. (Provision of subsidy by State Government): If the State Government requires the
grant of any subsidy to any consumer or class of consumers in the tariff determined by the State
Commission under section 62, the State Government shall, notwithstanding any direction which
may be given under section 108, pay, in advance and in such manner as may be specified, the
amount to compensate the person affected by the grant of subsidy in the manner the State
Commission may direct, as a condition for the license or any other person concerned to implement
the subsidy provided for by the State Government: Provided that no such direction of the State
Government shall be operative if the payment is not made in accordance with the provisions
contained in this section and the tariff fixed by State Commission shall be applicable from the
date of issue of orders by the Commission in this regard.”

Based on the ARR and sales projections approved by the Commission in the subsequent portion
of this order, the Commission has, based on the sample voltage vise losses submitted by the
Discoms, arrived at the estimated cost of service for supply at HT and LT voltage levels i.e. Rs.
6.12/Unit for HT Supply and Rs. 6.48/Unit for LT Supply. The calculation details have been
provided in the present order. In case the Government Haryana, as per past practice decides to
provide RE Subsidy u/s Section 65 of the Act on the tariff determined by this Commission under
Section 62 of the Electricity Act, 2003, under intimation to this Commission, it will have to pay in
advance, on a quarterly basis i.e. in April for the first quarter, in July for the second quarter, in
September for the third quarter and in December 2024 for the fourth quarter. Additionally, an
unpaid subsidy (committed and not paid or paid partly) will also have to be paid without any
further delay along with carrying cost for the period concerned at an interest rate as considered
by this Commission for working capital borrowings by the Discoms. Based on the cost of service
of LT consumers as given above and the approved estimate of sales to AP consumers, the
calculation of AP subsidy is as given below: -

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

RE Subsidy calculation unit value

1 AP Tube-well sales approved for FY 2024-25 MU 9325.21
2 Cost/ Tariff per unit Rs/kWh 6.48
3 Estimated cost of service Rs. Crores 6041.21
4 Revenue at existing subsidized tariff Rs. Crores 100.04
5 Subsidy required to keep the tariff at current levels = 3-4 Rs. Crores 5941.17

5.19 Revenue Surplus / Gap for ARR year FY 2024-25

Based on the revised estimates for Aggregate Revenue Requirement of Haryana Discoms and
proposed income, details of revenue gap for ARR year proposed by the utilities i.e. UHBVNL and
DHBVNL are tabulated as follows:

Proposed Revenue (Gap)/Surplus for ARR year for both Discoms (Rs Cr.)
Particulars UHBVNL DHBVNL Haryana
Aggregate Revenue Requirement 17,333.63 24076.71 41410.34
Revenue for Discoms 16,787.20 22994.32 39781.52
Sale of Power 13,902.23 20109.35 34011.58
Inter State Sales - - -
Subsidy from GoH 2,884.97 2,884.97 5769.94
Revenue Surplus/(Gap) (546.43) (1,082.40) (1,628.83)
Revenue surplus / (Gap)for FY 2022-23 (1,364.25)
Holding cost for 1.5 years @ 8.5% (173.94)
Revenue Surplus/(Gap) to be carried over (3,167.02)

Based on proposed and approved Aggregate Revenue Requirement and revenue from sale of
Power and AP Subsidy, revenue (gap)/surplus for ARR year FY 2024-25 for Haryana Discoms is
detailed as under:-

Approved Revenue (Gap)/Surplus for ARR year for both Discoms

Total ARR for FY 2024-25 FY 2024-25

UHBVNL Rs. Crore 18620.91
DHBVNL Rs. Crore 25642.36
Total ARR for FY 2024-25 (A) Rs. Crore 44263.27
Revenue at current tariff on intrastate sale Rs. Crore 35076.89
Revenue from Interstate State 0.00
Total Revenue (B) Rs. Crore 35076.89
Total Sales for FY 2024-25 (C) MU 61271.84
COS at LT level Rs per unit 6.48
AP sales for the FY 2024-25 MU 9325.21
Estimated Revenue from AP sales (E) Rs. Crore 100.04

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

AP subsidy at LT COS (F) Rs. Crore 5941.17

Subsidy for other consumers (G) Rs. Crore 0.00
Total revenue incl Subsidy (H=B+F+G) Rs. Crore 41018.06
Revenue surplus/(Gap) for FY 2024-25 at current tariff (H-A) Rs. Crore -3245.21
Surplus/Deficit on true up including holding cost for FY
Rs. Crore
2022-23
Holding cost for 1.5 years @ 8.5% Rs. Crore 0.00
Net Revenue Surplus/Gap for the FY 2024-25 Rs. Crore -3245.21
Recovery of revenue gap

Discoms, in their petition, submitted that the Aggregate Revenue Requirement for FY 2024-25 is
estimated based on the audited accounts for FY 2022-23 and in accordance with the HERC MYT
Regulations. For True-up year FY 2022-23, Haryana Discoms are in a revenue deficit of
Rs.1,364.25 Cr., whereas revenue deficit for APR year FY 2023-24 is Rs 2,342.56 Cr which would
be Rs 262.47 Crore after adjustment of revenue surplus of FY 2021-22 along with carrying cost.
ARR year FY 2024-25 has a revenue deficit of Rs 1628.83 Cr, which will increase to Rs 3167.02
Crore after adjustment of revenue gap estimated for the FY 2022-23 along with carrying cost.

UHBVNL, in its petition, has further submitted that the DISCOMs expect to recover some portion
of the revenue gap based on the distribution loss efficiency gain and purchase of power at low
cost in the APR year and especially in ARR year.

It has been submitted that Discoms are currently in the process of analyzing any requirement of
tariff modification. The same may be allowed to be submitted as an additional submission at a
later stage if required.

DHBVNL, in its petition, has submitted that DISCOMs expect to recover some portion of this Gap
based on the efficiency gain in APR and ARR years. The remaining revenue deficit can be covered
through long-term/short-term loans.

The Commission has considered the aforementioned submissions of the Discoms. At the onset
the Commission observes that as averred by UHBVNL that they may be allowed the liberty to
submit tariff proposal as a later stage in the form of additional submissions. However, the
distribution licensee viz. UHBVNL did not file any tariff proposal. The Commission for the
FY 2024-25, in line with the HERC MYT Regulations, earlier in this order, has approved the
quantum and cost of power purchase, all other expenses, RoE, consumer category wise sales,
system losses and amount to be true-up along with carrying cost. Accordingly, the revenue

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

requirement and revenue available from intrastate sale of power has been estimated and
approved by the Commission. Consequently, revenue balance for the FY 2024-25 is approved
as under: -

Rs. Crore
Sr. no Particulars Proposed Revenue Gap Approved
UHBVNL DHBVNL Discoms UHBVNL DHBVNL Total
1 Aggregate 17,333.63 24076.71 41410.34 18620.91 25642.36 44263.27
Revenue
Requirement
2 Revenue Discoms 16,787.20 22994.32 39781.52 41018.06
2.1 Sale of Power 13,902.23 20109.35 34011.58 35076.89
2.2 Inter State Sales 0 0 0 0
2.3 Subsidy 2,884.97 2,884.97 5769.94 5941.17
2.3.1 -Subsidy-AP 2,884.97 2,884.97 5769.94 5941.17
2.3.2 -Subsidy-Dom 0 0 0 0
3 Revenue -546.43 -1,082.40 -1,628.83 -3245.21
Surplus/(Gap)
4 FSA - - -
5 Net Revenue - - -1,628.83 -3245.21
Surplus/(Gap)
6 Revenue surplus -1,364.25 0.00
for FY 2022-23
7 Holding cost for -173.94 0.00
1.5 years @ 8.5%
8 Revenue -3,167.02 -3245.21
Surplus/(Gap) to
be carried over

After due deliberations, the Commission has considered the following to bridge the Revenue Gap
of Rs 3245.21 Crores at the existing tariff, as under:
Bridging of Revenue Gap (Rs Crores)
Revenue Surplus FY 2022-23 1061.57
Efficiency Gains 663.95
Estimated Revenue from MMC 130.00
Liquidation of Receivables (15% of defaulting amount as on Oct 2023) 1107.0
Total 2962.52#

#The balance revenue gap of Rs 282.69 crores shall be met from reduction of distribution losses
that has been pegged by the Commission at 10% in the FY 2024-25 i.e. reduction of a further
0.5% over and above 1.5% mentioned in the table above.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 6

CAPITAL EXPENDITURE AND TECHNICAL PARAMETERS

6.1 Capital Expenditure

6.1.1 True-up of Capital Expenditure for the FY 2022-23
UHBVNL
UHBVNL, in its present petition, has submitted that the Hon’ble Commission had approved a
capital expenditure of Rs. 970 Cr. for the FY 2022-23.

The petitioner has submitted that as per the audited account for FY 2022-23, the actual capital
expenditure is Rs. 743.82 Cr. Hence, UHBVNL has prayed that the Hon’ble Commission may
approve the same. Accordingly, the Commission approves the actual expenditure for FY 2022-23
as per audited accounts provided by the distribution licensee as enumerated in the following
table: -

Sr. Name of the Scheme FY 2022-23

No. Qty. Achieved Approved Expenditure
Cost incurred in FY UHBVNL Remarks
2022-23 (up to
31.03.2023)
A PD&C Wing
1 Creation of new 33 kV 44 12 Nos. 176.00 125.98 The target could not
sub-stations along with Nos. be achieved due to
Spill Over and non-availability of
associated 33 kV & 11 land. Now land has
kV lines including civil been made
works / Normal available by the (OP)
development (33 kV & wing. NIT has been
11 kV) floated for 21 Nos.
2 Augmentation of 67 39 Nos. 67.00 new 33 kV
existing 33 kV sub- Nos. Substations.
stations including civil Moreover, the land
works with Spill over for 12 Nos. new 33
3 Augmentation of 80 117.67 6.48 kV Substation is also
existing 33 kV lines km km being arranged and
NIT will be floated
shortly
4 Bifurcation/Trifurcation 45 6.75 7.00
of overloaded 11 kV
feeders
5 Release of tube well 3000 6890 37.50 113.81
connections on Turn Nos. Nos.
Key Basis

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Sr. Name of the Scheme FY 2022-23

No. Qty. Achieved Approved Expenditure
Cost incurred in FY UHBVNL Remarks
2022-23 (up to
31.03.2023)
6 Construction of 20.00 12.53
UHBVNL office /
residential Buildings
7 Civil allied Works other 2.00 5.31
than substation
buildings
8 LRP works (Urban 30.00 35.50
sanitization) and works
to be carried out under
MGJG scheme
9 Strengthening of 11 kV 80.00 50.50
lines, 11 kV Ring main
System, New DTs
10 Creation of double 80 32.00 0.00 The matter has been
supply source for 33 kV km deliberated in the
substations, 33 kV Ring Integrated Planning
main / Scada meeting as the
infra of connectivity
of second source is
to be created by
HVPNL & UHBVNL.
11 Revamped Distribution 33.86 0.00 NIT for LRP works
Strengthening Scheme have already been
(RDSS) floated and
evaluated. Draft
agendas have been
submitted for
approval of Hon'ble
Energy Minister.
The same will be put
up in coming High
Power Works
Purchase
Committee meeting
(State Level).
12 Electric Vehicle 0.32 0.27
Charging Station
Total A 491.91 350.90
B IT Wing
13 SCADA Implementation 30.00 Work was awarded
in Karnal & Panchkula to M/s Global
Electrical New Delhi
on 12.01.23 with
work order amount
of Rs. 26.74 Cr. The

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Sr. Name of the Scheme FY 2022-23

No. Qty. Achieved Approved Expenditure
Cost incurred in FY UHBVNL Remarks
2022-23 (up to
31.03.2023)
completion period
of the project was 9
months, but the
firm has executed
only 13 Nos.
foundation / plinth
for CSS. In the
meantime PBG
against the work
order submitted by
the firm was got
verified from the
Bank by SE (OP)
Karnal and it has
been found that the
same is fake. In view
of the above, work
order awarded to
the firm stands
terminated and FIR
against the firm has
been lodged. The
firm has also been
blacklisted for 5
years for doing the
business. The new
tender has been
floated at the Risk &
cost of the firm and
the due date of the
opening is
15.09.2023.
SCADA Implementation
Industrial Area Kundli
(HT & LT lines, DTs, U/G
Cables, RMU and FRTUs
etc.
14 Scaling of IT project to 4.80
Non R-APDRP areas
covering the following:
-
1. Establishment of IT 4.10
infra in SDO & Other
offices and its

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Sr. Name of the Scheme FY 2022-23

No. Qty. Achieved Approved Expenditure
Cost incurred in FY UHBVNL Remarks
2022-23 (up to
31.03.2023)
connectivity with Data
Center.
2. Commercial Data 0.40
Migration (IPDS &
Balance Areas)
15 RT-DAS SAIFI/SAIDI 14.44 9.78
Measurement System
in Non- SCADA, R-
APDRP, Non- RAPDRP
and IPDS Towns of
UHBVNL
16 ERP Implementation 20.00 0.00 Tender floated for
engagement of
ERP-PMA
1) Tender floated on
dated 17.05.2023
against NIT No.
39/SE/Projects/ERP-
PMA/RDSS/2023-
24.
2) Corrigendum-VIII
issued (Date
extended &
Amendments) on
dated 31.08.2023: -
Closing date of Part-
I: 14.09.2023
Opening date of
Part-I: 15.09.2023
Tender for ERP SI
will be floated after
engagement of
PMA
17 Smart Metering 25.00 33.98
18 AMR of HT Industrial 1.65 2.65
consumers
19 IT / OT works 10.00 0.00 The tendering
process of tech-
refresh project
under IT/OT works
being looked after
by DHBVNL on
behalf of both the
DISCOMs is under
process. The latest

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Sr. Name of the Scheme FY 2022-23

No. Qty. Achieved Approved Expenditure
Cost incurred in FY UHBVNL Remarks
2022-23 (up to
31.03.2023)
status is NIT has
already been
floated and
Technical
evaluation is under
process.
Opening date of
Part-I: 22.06.2023
Total B 106.29 50.51
C MM Wing
20 Procurement of single- 25.17 17.28
phase meters for
replacement of
defective meters &
release of new
connections.
21 Material required for 338.08 325.13
release of Non-AP
connections &
replacement of old
assets / system
improvement & normal
development
22 Procurement of Power 8.55 0.00
Transformers - 20 Nos.
along with allied
equipment such as 33
kV CTs - 45 Nos.
Total C 371.80 342.41
Gross proposed Capex 970.00 743.82
(A+B+C)
*The work is to be carried out at the 37.50
cost of the consumer
Total Capex 932.50

The Commission observes that the licensee has not been able to start 6 (six) important works at
sr. no. 10, 11, 13, 16 19 and 22 during the year for which an amount of Rs.134.41 Cr. was
approved by the commission. Further, in respect of the works mentioned at Sr. no. 7, 8, 17 and
18, the expenditure has been incurred more than the approved expenditure. The licensee has
merged expenditure for schemes at Sr. no. 1 to 3, against the individual scheme wise expenditure
approved by the Commission.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Supply of quality power is essential for distribution licensees. However out of 336.23 Cr. (Sr. No.
1,4,9) approved for augmentation / bifurcation / trifurcation and erection of new substations,
the actual capex undertaken has only about 54%.
The licensee has incurred expenditure of Rs.743.82 Cr. out of 970 Cr. approved capex for FY 2022-
23. There are some schemes/items, where expenditure have been incurred more than the
approved amount and for some of the approved schemes/items, no expenditure has been
incurred which reflects lack of proper execution of the capital works on the part of the licensee.
The licensee needs to exercise scheme wise monitoring of execution for capital works and control
the item wise expenditure approved by the Commission as per Regulation 8.3.3 (b) of the
Haryana Electricity Regulatory Commission (Terms and Conditions for Determination of Tariff for
Generation, Transmission, wheeling and Distribution & Retail Supply under Multi Year Tariff
Framework) Regulations, 2019.
Further, it is a matter of concern that the approved capex on RDSS did not materialize at all.
Needless to mention that the main objective of RDSS scheme is to reduce AT&C losses as well as
to eliminate the ACS-ARR gap through efficiency gain in the FY 2024-25.
DHBVNL
DHBVNL in its petition for true-up of FY 2022-23, APR of FY 2023-24 and ARR for FY 2024-25
submitted that the Hon’ble Commission had approved a revised Capital Expenditure of Rs.
1380.00 Cr. for FY 2022-23. As per the audited accounts, the actual Capital Expenditure incurred
during FY 2022-23 is Rs.1120.15 Cr. DHBVNL has prayed the Hon’ble Commission to approve the
same. The Commission approves the actual expenditure for FY 2022-23 as per details provided
by the Licensee presented in the following table:
Actual
Expenditure Revised CAPEX
Sr. Expenditure
Categories Approved in TO proposed in APR
No. incurred during
dt. 30.03.2023 for FY 2022-23
FY 2022-23
1 AT&C loss sustainable reduction
plan
a Procurement of single-phase
meters for replacement of
defective meters & release of new 37.32 37.32 36.82
connections and procurement of
Smart Meters.
b Procurement of three phase
meters for replacement of 11.68 11.68 12.17
defective meters & release of new

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Actual
Expenditure Revised CAPEX
Sr. Expenditure
Categories Approved in TO proposed in APR
No. incurred during
dt. 30.03.2023 for FY 2022-23
FY 2022-23
connections and procurement of
Smart Meters.
c Power Factor Improvement
(Providing automatic power 25.00 10.00 8.64
factor correctors)
Total 74.00 59.00 57.63
2 Load Growth schemes
a Creation of new 33 kV sub-
stations along with associated 33 150.00 76.48 76.41
kV & 11 kV lines
b Augmentation of existing 33 kV
50.00 35.29 38.17
sub-stations
c Augmentation of existing 33 kV
10.00 6.00 8.49
lines
d Bifurcation of 11 kV feeders
(Work of bifurcation of feeders, 110.00 88.29 81.91
augmentation of ACSR).
e Material required for release of
Non-AP connections & 209.95 209.95 215.21
replacement of old assets
f Release of Tube well connection
on turnkey basis and segregation
131.90 160.00 197.82
of AP load from Rural Urban
feeders.
g Procurement of power
transformers and allied
equipment such as 33 kV CTs, 33 40.00 40.00 43.59
kV PTs, 33 kV and 11 kV VCBs, 33
kV Control and Relay Panels etc.
Total 701.85 616.01 661.59
3 Other works
a Civil Works 30.00 8.19 10.47
b Mhara Gaon Jagmag Gaon
scheme for rural area and feeder
sanitization for Urban 140.00 153.35 163.00
area/LRP/Replacement of iron
pole.
c Other works for system
improvement - Procurement of IT 1.00 0.00 0.00
Equipment & Softwires
d Smart City Gurgaon (HT & LT
Lines, DTs, U/G Cables, RMUs and
360.00 277.60 191.02
FRTUs Etc.) including SCADA
Project, IMT, Manesar.
e Shifting of 11 lines passing over
9.76 4.20 3.13
residential areas under DHBVNL.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Actual
Expenditure Revised CAPEX
Sr. Expenditure
Categories Approved in TO proposed in APR
No. incurred during
dt. 30.03.2023 for FY 2022-23
FY 2022-23
f Double source of 33 KV Supply. 20.00 12.05 11.35
g Muffing of existing poles of 11 kV
6.89 0.07 0.05
lines
h Revamping of existing meter
testing laboratories operating at 5
towns of Dadri, Sirsa, Hisar, 7.48 4.00 0
Faridabad and Gurugram under
jurisdiction of DHBVNL
Total 575.13 459.46 379.02
R-APDRP Part-A (IT) Project
4 Scaling of IT project to Non-R-
APDRP areas covering the
following: -
1. Establishment of IT infra in SDO
& Other offices and its
connectivity with Data Center.
2. AMR for HT consumer meters.
3. Engagement of an Agency for
16.02 6.27 10.74
GPS based field survey activities &
data digitization.
4. Engagement of SI for DM.
5. Procurement of Computer
Furniture (Computer chair &
table) for office under IPDS town
and in balance non-R-APDRP
areas
5 RT-DAS (Real Time Data
13.00 9.26 11.17
Acquisition System)
Total 29.02 15.53 21.91
Grand Total 1380.00 1150.00 1120.15

The Commission observes that the DHBVNL could be able to achieve the capax targets during FY
2022-23 to the tune of 81.17% of the capital expenditure approved by HERC.
A perusal of the capital expenditure by the licensee during the FY 2022-23, reveals that for the
work mentioned at Sr. 2(e & f) the actual expenditure incurred has been more than the amount
approved by the Commission. The Licensee has not specified any reason or justification for the
deviations made from the approved Capex. It is further observed that no work has been started
for schemes/ works at Sr.no. 3 (c & h), related to IT infrastructure and revamping of meters
testing laboratories which is urgently required to enhance the efficiency of the system.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

As per Regulation 8.3 (b) of the Haryana Electricity Regulatory Commission (Terms and
Conditions for Determination of Tariff for Generation, Transmission, Wheeling and Distribution
& Retail Supply under Multi Year Tariff Framework) Regulations, 2019, capital expenditure is a
controllable item. As such the licensee should have exercised proper control over the item wise
Capital Expenditure approved by the Commission.
Regulation 9.10 of the Haryana Electricity Regulatory Commission (Terms and Conditions for
Determination of Tariff for Generation, Transmission, Wheeling and Distribution & Retail Supply
under Multi Year Tariff Framework) Regulations, 2019 further specifies as under: -
“In case the capital expenditure incurred for approved schemes exceeds the amount as
approved in the capital expenditure plan, the generating company or the transmission
or the distribution licensee, as the case may be, shall file an application with the
Commission at the end of control period for truing up the expenditure incurred over
and above the approved amount. After prudence check, the Commission shall pass an
appropriate order on case to case basis. The True-up application shall contain all the
requisite information and supporting documents”.
Provided that any additional capital expenditure incurred on account of time over run
and / or on unapproved schemes not covered under regulation 9.9 or unapproved
changes in scope of approved schemes shall not be allowed by the Commission unless
the generating company or the licensee, as the case may be, is able to give adequate
justification for the same”.
The Present control period of HERC MYT Regulations in vogue ends on 31/03/2025. Hence the
distribution licensee shall submit a true-up application as per the provision of the Regulations
supra alone with detailed justification including incremental benefits flowing from additional
Capex.

6.1.2 Review of Capital Investment Plan in progress for FY 2023-24

Regulation 9.7 of the Haryana Electricity Regulatory Commission (Terms and Conditions for
Determination of Tariff for Generation, Transmission, Wheeling and Distribution & Retail Supply
under Multi Year Tariff Framework) Regulations, 2019, specifies that in the normal course, the
Commission shall not revisit the approved capital investment plan during the control period.
However, during the mid-year performance review and True-up, the Commission shall monitor
the year wise progress of the actual capital expenditure incurred by the generating company or

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

the licensee vis-à-vis the approved capital expenditure and in case of significant difference
between the actual expenditure vis-a-vis the approved expenditure, the Commission may True-
up the capital expenditure, subject to prudence check, as a part of annual True-up exercise on or
without an application to this effect by the generation company/licensee. The generating
company and the licensee shall submit the scheme-wise actual capital expenditure incurred along
with the mid-year performance review and True-up filing.
Accordingly, both the DISCOMs, by way of the instant Annual Performance Review petitions for
the FY 2023-24 and subsequent submissions made in this regard, have revised their capital
investment plan for the FY 2023-24. After due deliberations on the proposed CIP (revised), the
Commission allows the following revised capital investment plans.
UHBVNL
UHBVNL has submitted that the Hon’ble Commission, in Tariff Order dated 15.02.2023, had
approved Capital Expenditure Plan Rs. 1000 Crores for the year FY 2023-24. Against the said
approval, an amount of Rs. 413.56 Cr. Only has been spent during FY 2023-24 in the first half (up
to Sept. 2023) and balance is likely to be incurred in the second half, ending March, 2024 as per
the following details:
FY 2023-24
Expenditure incurred
Sr. Revised Revised in FY 2023-24
No. Name of the Scheme Qty. Cost Equity (up to 30.09.2023)
A PD&C Wing
Creation of new 33 kV sub-stations alongwith
1 Spill Over and associated 33 kV & 11 kV lines 25 Nos. 100.94 20.19
including civil works / Normal development
(33 kV & 11 kV) 35.27
2 Augmentation of existing 33 kV sub-stations 40 Nos. 50.00 10.00
including civil works
3 Augmentation of existing 33 kV lines 56 km 4.06 0.81
4 Release of tube well connections on Turn Key 3000 Nos. 37.50 0.00 28.96
Basis*
5 Construction of UHBVNL office / residence 15.00 3.00
Buildings
6 Civil Works other than substation buildings 2.00 0.40 1.66
LRP works (Urban sanitization) and works to
7 be carried out under MGJG scheme 20.00 4.00 15.67
8 RDSS (Revamped Distribution Sector 138.27 27.65
Scheme)
9 EV Charging station 2.00 0.40
10 11 KV (Others) 75.00 15.00 53.37
Total A 444.77 81.45 134.93

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

FY 2023-24
Expenditure incurred
Sr. Revised Revised in FY 2023-24
No. Name of the Scheme Qty. Cost Equity (up to 30.09.2023)
B IT Wing
Installation of Smart Meter in Panchkula,
11 Karnal & Panipat towns by M/s EESL 31.00 6.20 25.02
12 Installation of Smart Meter in UHBVNL 175.00 35.00 0.00
13 ERP Implementation 20.00 4.00 0.00
14 AMR of HT Industrial Consumers 2.20 0.44 0.87
Total B 228.20 45.64 25.89
C MM Wing
Procurement of single-phase meters for
15 replacement of defective meters & release of 32.13 6.43
new connections.
Material required for release of Non-AP
16 connections & replacement of old assets / 283.26 56.65
system improvement & normal development 252.74
17 Procurement of Power Transformers -20
Nos. along with allied equipment such as 33 11.64 2.33
kV CTs - 30 Nos.
Total C 327.03 65.41 252.74
Gross proposed Capex (A+B+C) 1,000.00 192.50 413.56

The Commission observes that no expenditure has been indicated for scheme at Sr. no. 12 and
13 for which an amount of Rs. 195 Cr. was approved by the Commission. The licensee is required
to give reasons for no progress against these works during the FY 2023-24. Further the licensee
has merged the various schemes and shown the cumulative expenditure together (e.g. merged
schemes at Sr. no. 1 to 3, and 15 to 17), against the individual scheme wise expenditure approved
by the Commission.

In view of above MYT Regulation 2019 which specifies that normally, the Commission will not
revisit the approved capital investment plan during the control period. However, during the mid-
year performance review and True-up, the Commission will monitor the year wise progress of
the capital expenditure incurred by the generating company or the licensee vis-à-vis the
approved capital expenditure and in case of significant difference between the actual
expenditure vis-a-vis the approved expenditure, the Commission may True-up the capital
expenditure, subject to prudence check, as a part of annual True-up exercise on or without an
application to this effect by the generation company/licensee. The generating company and the

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

licensee shall submit the scheme-wise actual capital expenditure incurred along with the mid-
year performance review and True-up filing.

It is a matter of concern that as crucial works related to operating efficiency of the distribution
licensee listed at Sr. A(1-10), progress in the first half is tardy leaving about 70% of the Capex to
the 2nd half of the financial year. Such execution of work reveals lack of seriousness which ought
to be avoided. The distribution licensee is directed to explain the entire gamut of planning
including an updated Capex table and justification for no expenditure on the Capex proposed by
them and approved by the Commission immediately after close of the FY 2023-24.

DHBVNL
DHBVNL submitted that the Commission in tariff order dated 15.02.2023 had approved Capital
Expenditure Plan of Rs. 1200 Cr. for FY 2023-24. However, the petitioner has revised Capital
Expenditure in schemes but kept the total expenditure same as Rs. 1200 Cr. for computing the
revised estimate of ARR component for FY 2023-24.
DHBVNL submitted that out of total capital expenditure of Rs. 1200 Cr., the amount of Rs. 598.85
Cr. has been incurred during FY 2023-24 in the first half (up to Sept. 2023) and balance of Rs.
601.15 Cr. likely to be incurred in the second half, ending March, 2024 as per the following
details:
Sr. Description CAPEX Expenditure Expected Total
No. Approved incurred in Expenditure CAPEX
in TO dt. H1 of for H2 of proposed
15.02.23 FY2023-24 FY2023-24 for FY
for FY 2023-24
2023-24
1 AT&C loss sustainable reduction plan
a Procurement of single-phase meters
for replacement of defective meters
40.00 29.46 4.40 33.86
& release of new connections and
procurement of Smart Meters.
b Procurement of three phase meters
for replacement of defective meters
12.00 8.68 6.52 15.20
& release of new connections and
procurement of Smart Meters.
c Power Factor Improvement
(Providing automatic power factor 10.00 6.45 3.55 10.00
correctors)
Sub Total 62.00 44.59 14.47 59.06
2 Load Growth schemes

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Sr. Description CAPEX Expenditure Expected Total

No. Approved incurred in Expenditure CAPEX
in TO dt. H1 of for H2 of proposed
15.02.23 FY2023-24 FY2023-24 for FY
for FY 2023-24
2023-24
a Creation of new 33 kV sub-stations
along with associated 33 kV & 11 kV 90.00 23.84 25.30 49.14
lines
b Augmentation of existing 33 kV sub-
75.00 24.93 30.85 55.78
stations
c Augmentation of existing 33 kV lines 22.69 13.41 5.06 18.47
d Bifurcation of 11 kV feeders (Work of
bifurcation of feeders, augmentation 90.00 30.75 52.54 83.29
of ACSR).
e Material required for release of Non-
AP connections & replacement of old 226.00 242.44 107.94 350.38
assets
f Release of Tube well connection on
turnkey basis and segregation of AP 130.00 52.38 83.38 135.76
load from Rural Urban feeders.
g Procurement of power transformers
and allied equipment such as 33 kV
40.00 14.98 24.71 39.69
CTs, 33 kV PTs, 33 kV and 11 kV VCBs,
33 kV Control and Relay Panels etc.
Sub Total 673.69 402.72 329.78 732.50
3 Other works
a Civil Works 25.00 8.01 16.98 25.00
b Mahara Gaon Jagmag Gaon scheme
for rural area and feeder sanitization
140.00 75.03 66.17 141.20
for Urban area/ LRP/ Replacement of
iron pole.
c Smart City Gurgaon (HT & LT Lines,
DTs, U/G Cables, RMUs and FRTUs
250.00 56.73 123.00 179.73
Etc.) including SCADA Project, IMT,
Manesar.
d Shifting of 11 lines passing over
9.14 0.43 10.30 10.72
residential areas under DHBVNL.
e Double Source of 33 KV Supply 10.00 4.15 3.50 7.65
f Muffing of existing poles of 11 KV
5.00 0.03 0.70 0.73
Lines
g Revamping of existing meter testing
laboratories operating at 5 towns of
Dadri, Sirsa, Hisar, Faridabad and 11.68 0.00 14.54 14.54
Gurugram under jurisdiction of
DHBVNL
Sub Total 450.82 144.38 235.19 379.58
4 Scaling of IT project to Non-R-APDRP
areas covering the following: - 9.75 5.12 19.63 24.75
1. Establishment of IT infra in SDO &

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Sr. Description CAPEX Expenditure Expected Total

No. Approved incurred in Expenditure CAPEX
in TO dt. H1 of for H2 of proposed
15.02.23 FY2023-24 FY2023-24 for FY
for FY 2023-24
2023-24
Other offices and its connectivity
with Data Center.
2. AMR for HT consumer meters.
3. Engagement of an Agency for GPS
based field survey activities & data
digitization.
4. Engagement of SI for DM
5. Procurement of Computer
Furniture (Computer chair & table)
for office under IPDS town and in
balance non-R-APDRP areas
5 RT-DAS (Real Time Data Acquisition
3.74 2.03 2.08 4.11
System)
Sub Total 13.49 7.15 21.71 28.86
Grand Total 1200.00 598.85 601.15 1200.00

The Commission observes that there is no indication of expenditure on the works mentioned in
CIP at Sr. No. 3 (g) for first half and minuscule expenditure of 0.03 Cr against approved capex of
Rs 5 Cr. at sr. No. 3(f) and 0.43 Cr. against approved capex or Rs. 9.14 Cr. at sr. No. 3(d) has been
shown. The licensee is directed to provide the reasons/ justification for no progress against these
works during FY 2023-24.

6.1.3 Capital Investment Plan (FY 2024-25)

The licensees have submitted the capital investment plan for FY 2024-25 as per following details:
UHBVNL
UHBVNL has submitted that the investment plan for the ARR year includes capital works towards
load growth, strengthening of distribution network, reduction of distribution losses,
improvement of system reliability, strengthening of IT infrastructure, system automation, smart
metering, digitalisation of business processes, EV charging infrastructure, rural electrification,
release of AP tube well connections etc.
The element wise details of Capital Expenditure proposed by UHBVNL for ARR year is tabulated
as follows:-

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FY 2024-25
Sr.
Name of the Scheme Cost (Rs.
No. Qty. Funding Agency
Cr.)
A PD&C Wing
Creation of new 33 kV sub-stations along with spill over
30
1 and associated 33 kV & 11 kV lines including civil works 165.00 REC/ RDSS
Nos.
/ Normal development (33 kV & 11 kV)
Augmentation of existing 33 kV sub-stations including 50
2 62.50 REC/ RDSS
civil works Nos.
3 Augmentation of existing 33 kV lines 35 km 3.32 REC
1000 Consumer Cost /
4 Release of tube well connections on Turnkey Basis 12.50
Nos. Deposit work
5 Civil allied Works other than substation buildings 10.00 REC
6 RDSS (Revamped Distribution Sector Scheme) 300.00 RDSS
REC/Nigam
7 EV Charging Station 2.00
Fund
Total A 555.32
B IT Wing
System Integrator (ERPSI) for Supply, Installation,
8 Commissioning, Implementation and Support for 6.00
Enterprise Resource Planning (ERP) System at UHBVNL RDSS
9 SCADA/DMS implementation 70.00
10 IT/OT Works 30.00
11 Smart Metering 130.00 Nigam Fund
Total B 236.00
C MM Wing
Material required for release of Non-AP connections &
REC/ NABARD
11 replacement of old assets / system improvement & 360.00
etc
normal development
Total C 360.00
Gross proposed Capex (A+B+C) 1,151.32
The work is to be carried out at the cost of the consumer 12.50
Total Capex 1,138.82

DHBVNL
DHBVNL has submitted that Capital Expenditure Plan for FY 2024-25 is proposed with a focus on
strengthening of the distribution network, reduce distribution losses and increase IT
implementation. The Capital Investment plan for the ARR year is planned to be funded from
equity infusion by Government of Haryana/Discoms, debt funding by financial institutions such
as REC & PFC, and corporate banks such as SBI, Central Bank of India and Indian Bank and
consumer contribution. Scheme Wise Capital Expenditure Plan of DHBVNL is tabulated as under:-
-

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Quantity Proposed
Sr.
Description (in Nos/ CAPEX for FY
No.
KMs.) 2024-25
1 AT&C loss sustainable reduction plan
a Procurement of single-phase meters for replacement of
defective meters & release of new connections and procurement 80.00
of Smart Meters.
b Procurement of three phase meters for replacement of defective
meters & release of new connections and procurement of Smart 30.00
Meters.
c Power Factor Improvement (Providing automatic power factor
25.00
correctors)
Sub Total 135.00
2 Load Growth schemes
a Creation of new 33 kV sub-stations along with associated 33 kV
40 100.00
& 11 kV lines
b Augmentation of existing 33 kV sub-stations 60 80.00
c Augmentation of existing 33 kV lines 100 20.00
d Bifurcation of 11 kV feeders (Work of bifurcation of feeders,
133.00
augmentation of ACSR).
e Material required for release of Non-AP connections &
363.06
replacement of old assets
f Release of Tube well connection on turnkey basis and
159.83
segregation of AP load from Rural Urban feeders.
g Procurement of power transformers and allied equipment such
as 33 kV CTs, 33 kV PTs, 33 kV and 11 kV VCBs, 33 kV Control and 21.11
Relay Panels etc.
Sub Total 877.00
3 Other works
a Civil Works 70.00
b MGJG scheme for rural area and feeder sanitization for Urban
130.00
area/LRP/Replacement of iron pole.
c Other works for system improvement - Procurement of IT
2.00
Equipment & Software
d Smart City Gurgaon (HT & LT Lines, DTs, U/G Cables, RMUs and
180.00
FRTUs Etc.) including SCADA Project, IMT, Manesar
e Shifting of 11 lines passing over residential areas under DHBVNL. 15.00
f Double Source of 33 KV Supply 8.00
g Muffing of existing poles of 11 KV Lines 1.00
Sub Total 406.00
4 App Upgradation of CCB 15.00
5 Hardware Refresh of Data Centre 10.00
System Integrator (ERPSI) for supply, Installation,
6 Commissioning, Implementation and Support for ERP system at 7.00
DHBVNL
Sub Total 32.00
Grand Total 1450.00
The work is to be carried out at the cost consumer 159.83
Total Capex 1290.17

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DHBVNL has not submitted the scheme wise details regarding financial tie ups to carry out the
proposed Capital Expenditure plan. Further the both DISCOMs has not given the status of NITs/
tenders and activities undertaken to implement the CIP during FY 2024-25.
It is noted that a major part under RDSS schemes are centrally funded, only the counterparty
fund (debt/equity) has to be arranged by the licensees Discoms. Both the Discoms may provide
the scheme wise break-up of the funding mechanism.
UHBVNL has proposed a capital expenditure plan of Rs. 1151.32 Cr. for FY 2024-25. The
Commission observes that UHBVNL has been able to incur an expenditure of Rs. 864.52 Cr.
against approved Rs. 1028 Cr. (84.10%) during FY 2019-20, Rs. 875.30 Cr. against approved Rs.
980 Cr. (89.32%) during FY 2020-21, Rs. 947.37 Cr. against approved Rs. 950 Cr. (99.72%) during
FY 2021-22 and Rs. 743.82 Cr. against approved Rs. 970 Cr. (76.68%) during FY 2022-23. The
average percentage of four years comes out to be 87%. UHBVNL has incurred expenditure of
Rs.413.56 Cr. only in first half of FY 2023-24 ending Sept, 2023. The Commission feels that
adequate capital expenditure is required to meet the loss reduction targets and to strengthen
the distribution system and implementation smart metering along with other project for
digitalization of business process of licensee. Keeping in view of the above facts, the Commission
approves an overall Capital Expenditure plan of Rs. 1036 Cr. for UHBVNL for FY 2024-25, which
includes work of Rs. 12.50 Cr. to be carried out as deposit works by consumers.
The Licensee is directed to revise its Capital expenditure plan accordingly and submit the
scheme wise details of the proposed expenditure to the Commission within one month of the
Order.
Further, DHBVNL, has proposed a capital expenditure plan of Rs.1450.00 Cr. for FY 2024-25. An
expenditure of Rs. 1101.61 Cr. against approved Rs. 1220 Cr. (90.30%) during FY 2019-20, Rs.
958.37 Cr. against approved Rs. 1200 Cr. (79.86%) during FY 2020-21, Rs. 978.79 Cr. against
approved Rs. 1125 Cr. (87%) during FY 2021-22 and Rs. 1120.15 Cr. against approved Rs. 1380
Cr. (81.17%) during FY 2022-23 has been incurred by DHBVNL. The average percentage of four
years comes out to be 85%. For FY 2023-24, the Licensee has stated in its submissions that
expenditure of Rs.598.85 Cr. only has been incurred in first half of FY 2023-24 ending Sept, 2023
and further Rs. 601.15 Cr. are likely to be spent from Oct, 2023 to March, 2024. Keeping in view
of submissions of the Licensee and expenditure incurred against approved expenditure, the
Commission approves the capital expenditure to tune of Rs. 1276 Cr. for FY 2024-25, it includes

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

work of Rs. 159 Cr. to be funded from consumers contribution. The licensee is directed to revise
its capital expenditure plan accordingly and to submit the scheme wise details along with funding
details of proposed expenditure to the Commission within one month from the date of issue of
this Order.
The distribution licensees are directed to reckon with their Capital Expenditure Plans for the
FY 2024-25 as per regulations 9.7 to 9.12 of the Haryana Electricity Regulatory Commission
(Terms and Conditions for Determination of Tariff for Generation, Transmission, Wheeling and
Distribution & Retail Supply under Multi Year Tariff Framework) Regulations, 2019.

6.2 Review of Technical Parameters

The Commission has reviewed the performance of distribution system of the Haryana DISCOMs
based on the details made available for the FY 2022-23 and the FY 2023-24. Further, the
projections for the FY 2024-25 based on filing of their True up for the FY 2022-23, Annual
Performance Review of 2023-24 and proposed Aggregate Revenue Requirement for the FY 2024-
25 along with subsequent filings as per Multi Year Tariff Regulations in vogue has been examined
at length. The observations of the Commission in these regards are as follows: -
Distribution Losses
The year-wise position of distribution losses as per the time series data provided by the
distribution licensee(s) is presented in the table below: -
Financial Year UHBVNL DHBVNL
2015– 2016 31.49% 24.47%
2016–2017 29.86% 22.49%
2017– 2018 24.81% 19.16%
2018– 2019 22.04% 15.34%
2019– 2020 19.01% 14.37%
2020–2021 17.21% 16.93%
2021-2022 13.96% 13.55%
2022-2023 10.32% 11.42%

It is evident from the distribution loss data (supra) that the distribution loss of UHBVNL &
DHBVNL have decreased over the years. The Commission observes that distribution loss
reduction is one of the key factors for financial sustainability of Discoms and expects that the
Distribution Licensee(s) shall make concerted efforts to achieve the distribution loss targets fixed
by the Commission by taking various initiatives including capital expenditure on system

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

strengthening/ up gradation, installation of new technology-based energy meters, IT /AI

interventions as well.
Feeder Losses
The year-wise position of line losses on 11kV Rural and Urban feeders of the licensee(s), as per
the information provided, is tabulated as under: -

a) Urban Feeder(s) -Losses

Year FY 2021-22 FY 2022-23 FY 2022-23 FY 2023-24

(Apr-Sept.) (Apr-Sept.)

DISCOM UHBVN DHBVN UHBVN DHBVN UHBVN DHBVN UHBVN DHBVN

Total Feeders 838 973 880 996 880 985 904 1030
Feeders with losses > 25% 24 28 4 19 30 55 6 68
Feeders with losses > 25% (in %age) 2.86 2.88 0.45 1.90 3.41 5.58 0.66 6.60
b) RDS Feeders -Losses

Year FY 2021-22 FY FY 2022-23

2022-23 FY 2023-24
(Apr-Sept.) (Apr-Sept.)
DISCOM UHBVN DHBVN UHBVN DHBVN UHBVN DHBVN UHBVN DHBVN
Total Feeders 1059 1127 1099 1154 1099 1145 1116 1177
Feeders with losses >50% 178 279 92 227 229 291 77 276
Feeders with losses >50% (in 16.81 24.76 8.37 19.67 20.84 25.41 6.90 23.45
%age)

The statistics provided by the licensee(s) reveals that the number of urban feeders reporting
losses more than 25% and rural feeders reporting losses more than 50% for the FY 2023-24 vis-
a-vis the corresponding period of FY 2022-23 has reduced in UHBVN but increased in DHBVN. It
is observed that DISCOMs are far away from achieving the target set for the purpose, to bring
down losses of all feeders to below than 25% in Urban and 50% in case of the Rural area.
It needs to be noted that the Commission, vide tariff order dated 15/02/2023, had directed the
DISCOMs to reduce the AT&C losses and to bring all urban feeders below 25% and rural feeders
below 50% in the FY 2023-24 and submit a status report for the FY 2022-23 within 2 months of
the order.
UHBVN, vide memo no. Ch-33/RA/F-173/Vol-14 dated 24.04.2023, submitted as under:
FY 2021-22 FY 2022-23
Year
(as on 31.03.2022) (as on 31.03.2023)
Urban Feeder(s)
Total Feeders 838 880
Feeders with losses > 25% 24 4

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FY 2021-22 FY 2022-23
Year
(as on 31.03.2022) (as on 31.03.2023)
Feeders with losses > 25% (in %age) 2.86 0.45%
Rural Feeder(s)
Total Feeders 1059 1099
Feeders with losses >50% 178 92
Feeders with losses >50% (in %age) 16.81 8.37%
DHBVN, vide memo no Ch-59/SE/RA-761 dated 16.05.2023, submitted as under:
FY 2021-22 FY 2022-23
Year
(as on 31.03.2022) (as on 31.03.2023)
Urban Feeder(s)
Total Feeders 973 996
Feeders with losses > 25% 28 21
Feeders with losses > 25% (in %age) 2.88% 2.11%
Rural Feeder(s)
Total Feeders 1127 1154
Feeders with losses >50% 279 227
Feeders with losses >50% (in %age) 24.76% 19.67%
Circle RDS Feeder Urban Feeder
As per the aforesaid submission, DHBVN is implementing two major loss reduction schemes
namely:

A. Mhara Gaon Jagmag Gaon Scheme (MGJG) for Rural feeders

B. Loss Reduction Plan (LRP) for Urban feeders

DHBVNL’s Action Plan to reduce T&D losses:

• Detection of theft.

• Mass drive to replace the defective & electro-mechanical meters:

• Relocation of meters outside consumers premises, feeder wise, and effective

sealing thereof.

• Replacement of ACSR with Cable in theft prone area / colonies.

• Providing reference meters in the colonies / housing complexes (societies).

• Cross checking of meter readings taken by MRBD Agency.

• Checking of MDI of the temporary connections and MF of HT / LT Consumers.

• Creation of centralized cell to audit the accounts of Open Access Consumers.

• Operationalization of technical audit to keep check on the quality & quantity of

material & workmanship of the works.

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• Fixation of targets at Sub-Division level to improve the Billing efficiency &

monitoring thereof.

• Implementation of LRP Scheme in Urban feeders

• Implementation of Mahara Gaon Jagmag Gaon Scheme activity in Rural feeders.

It has been submitted that the MGJG and loss reduction activity has been implemented in most
of the feeders. Currently, MGJG activity in 215 rural feeders is under progress and work for 66
rural feeders is yet to start. Nigam officials are facing resistance in implementing MGJG works in
some problematic villages, which has resulted in delay in completion of work. Although there is
some improvement yet the feeders with higher losses are still existing.
The Commission has considered the above and observes that as per the directive, there should
be no urban feeder with losses more than 25% and rural feeder with losses more than 50 %.
However, it is observed that in UHBVNL as on 31.03.2023, out of total 880 Urban feeders, there
were 4 (0.45%) Urban feeders having loss more than 25% category whereas there were 92
(8.37%) RDS feeders in Rural category having loss more than 50% out of a total of 1099 Rural
feeders.
In DHBVN as on 31.03.2023, out of total 996 Urban feeders there were 19 (1.90%) Urban feeders
having loss more than 25% whereas in Rural category there are 227 (19.67%) RDS feeders having
loss more than 50% out of a total of 1154 Rural feeders. However as on September 2023,
percentage of higher feeder loss increased from 1.90% to 6.60% in Urban and 19.67% to 23.45%
in Rural Areas.

The Commission directs the DISCOMs to make all out efforts to reduce AT&C losses of all urban
feeders below 25% and that of Rural feeders below 50%.

6.3 Loss Reduction Trajectory

The DISCOMs in present petition(s) for ARR and tariff determination for the FY 2024-25, annual
performance review (APR) for FY 2023-24 and true up for FY 2022-23 as per multiyear tariff
mechanism, have submitted the progress (Actual/projections) of distribution loss, collection
efficiency (CE) and AT&C as under: -

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

DISCOM UHBVNL DHBVNL

Distribution Collection AT& C Distribution Collection AT & C
Loss Efficiency Loss Loss Efficiency Loss
Year (%) (%) (%) (%) (%) (%)
2019-20
19.01 99.26 19.61 14.37 98.79 15.41
2020-21
17.21 100.79 16.55 16.93 101.16 15.97
2021-22
13.96 101.46 12.70 13.55 101.12 12.59
2022-23
10.32 100.00 10.32 11.42 97.13 13.96
2023-24
12.00 99.50 12.50 12.00 99.50 12.50
(Approved)
2024-25
10.75 99.50 11.20 10.75 99.50 11.20
(Proposed by DISCOM)
The regulation (57.2) of HERC MYT Regulations in vogue provide for the following regulatory
benchmarks:
Collection Efficiency (%)
Distribution FY FY FY FY FY
Licensee 2020-21 2021-22 2022-23 2023-24 2024-25
UHBVNL 99.5 99.5 99.5 99.5 99.5
DHBVNL 99.5 99.5 99.5 99.5 99.5
The Commission in its Tariff Order dated 30.03.2022, had considered and approved the
distribution loss of 14% and AT&C loss of 14.50% and collection efficiency norms of 99.5% for the
FY 2022-23. The Commission sought the actual AT&C Loss and actual collection efficiency along
with the details of net input energy / net billed energy for FY 2022-23 from the petitioners.
Accordingly, the petitioners had submitted the said information:
AT&C Loss Calculation for FY 2022-23
Particulars UHBVNL DHBVNL
Net Input Energy (In MU) 24147.74 35004.82
Net Billed energy (In MU) 21654.66 31008.28
Distribution Loss 10.32% 11.42%
Collection Efficiency 100.00% 97.13%
AT&C Losses 10.32% 13.96%
It can be seen from the table above that the Discoms viz. UHBVN and DHBVN have achieved
distribution loss level of 10.32% and 11.42% respectively against the target of 14% as approved
by the Commission in the Tariff Order dated 30.03.2022.
UHBVNL has submitted that Nigam has taken various initiatives to rein in the distribution losses
even below the permissible range in FY 2022-23. Activities like replacement of defective meters,

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

preventive maintenance of distribution transformers, feeder sanitization of urban and rural

areas, strengthening of LT& HT network, bifurcation and trifurcation of feeders, creation &
augmentation of 33/11 KV network, installation of Automatic Power Factor Control (APFC),
online delivery of citizen services and surprise vigilance drive has been aggressively implemented
to minimise the technical and commercial losses of UHBVN. Special thrust has been given to
strengthen IT enabled services, activities such as feeder metering with AMR enabled meters, spot
billing in urban subdivisions, roll out of trust billing, migration of billing data on IT platform, online
payment of energy bills, smart metering and SCADA in urban areas has been extended to
enhance the efficiency. Further, Mhara Gaon Jagmag Gaon (MGJG) Scheme has been the flagship
scheme that has helped Nigam to reduce the losses in rural areas tremendously.
DHBVNL has submitted that they have implemented Mhara Gaon Jag Mag Gaon (MGJG) and
Feeder Sanitization Schemes in both rural and urban areas to curb power theft and to improve
upon the quality of supply to the consumers. It is noted that Line losses of Rural Domestic
Feeders (RDS) contribute significantly to the distribution losses. Therefore, to minimize overall
distribution losses, DHBVN had implemented MGJG scheme on RDS feeders. As per the said
scheme, on achievement of line losses less than 20% and defaulting amount less than 10%,
power supply of 24 hours would be made available to the villages. Further, DHBVN is in the
process of installing 5 lakh smart meters in Gurugram and Faridabad under OPEX Model through
Energy Efficiency Services Limited (EESL) which is promoted by the Ministry of Power, Govt. of
India. During FY 2022-23, DHBVN has achieved distribution loss level of 11.42%, which is lower
than the distribution loss target of 14% given by the Hon'ble Commission in its Tariff Order dated
30th March 2022. In view of the above, it has been submitted that the Hon'ble Commission may
consider the actual distribution loss level of DHBVN for carrying out the true up for the FY 2022-
23.
The DISCOMs have further submitted that the Hon'ble Commission in consideration of the above
submission, may allow the gain sharing in the ratio of 50:50 to DHBVNL for achievement of
performance target of distribution losses while truing up of ARR for FY 2022-23 in accordance
with Regulation 12.4 of HERC MYT Regulations, 2019.
It needs to be noted that AT&C loss target was relaxed by the Commission and fixed at 14% for
FY 2022-23 in view of spread of Corona Virus pandemic which had adversely affected the HT, LT
consumption mix. Post Covid, the consumption, especially of C&I consumers have seen a surge

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where distribution losses are on the lower side. Therefore, given the facts and circumstances,
the Commission does not find it appropriate to consider licensee(s) for incentive as such and the
relief, if any, ought to go to the electricity consumers of Haryana.
Further, the petitioners have submitted unaudited figures of AT &C loss and collections efficiency
from April to September,2023 as under: -
AT&C loss Calculation for FY 2023-24 (1st half Yr. i.e. April to September)

Particulars UHBVNL DHBVNL

Net Input Energy (In MU) 13370.41 20914.90
Net Billed energy (In MU) 11916.01 16671.10
Distribution Loss 10.88% 20.29%
Collection Efficiency 97.77% 96.36%
AT&C Losses 12.87% 23.19%

It is observed that the AT & C loss of DISCOMs for the first half (H1) of FY 2023-24 is on higher
side against the projections for FY 2023-24. However, in general also, trend for AT&C loss in first
half (H1) always remains on higher side as compared to 2nd half (H2). Further UHBVN and DHBVN
in their proposal for FY 2023-24 requested to consider the distribution loss of 12% as approved
by the Commission vide Order dated 15.03.2023. The Commission retains Distribution, Collection
Efficiency & AT&C loss for FY 2023-24 as approved vide T.O. dated 15.02.2023.
Further the licensees for FY 2024-25 have considered the collection efficiency as per the MYT
Regulations,2019 and accordingly proposed the distribution loss and AT&C loss as under:
DISCOMs UHBVNL DHBVNL
Distribution Loss 10.75% 10.75%
Collection Efficiency 99.50% 99.50%
AT&C Losses 11.20% 11.20%
The Commission, after considering the submission made by DISCOMs and various stake holders
during the public hearing, considering the performance in 2023-24 and further examining the
matter placed on record and the Capex targeted at distribution loss reduction, consider it
appropriate to peg the distribution loss as 10.00% for both UHBVNL & DHBVNL respectively and
collection efficiency of 99.5% as per MYT Regulations, 2019 for the FY 2024-25 as under:
DISCOM UHBVNL DHBVNL
Distribution Loss (in %) 10.00 10.00
Collection Efficiency (in %) 99.50 99.50
AT&C Loss Target (in %) 10.45 10.45

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

6.4 Distribution Transformers (DTs) failure rate:

The HERC, (Standards of Performance of Distribution Licensees and Determination of

Compensation) Regulations,2020 at regulation (6.1.e) specifies that the distribution Licensee
shall have to maintain the transformer damage rate below 3% p.a. in urban area and 6% p.a. in
rural area. The year-wise status of damage rate of distribution transformers, as per the
information provided by UHBVNL and DHBVNL, is as under: -
Distribution Transformers Failure Rate
Year UHBVNL DHBVNL
Failure Failure Failure Rate Failure
Rate excluding Rate including excluding Rate including
transformers transformers transformers transformers
damaged within damaged within damaged within damaged within
warranty period warranty period warranty period warranty period
(%) (%) (%) (%)
2019-20 Urban 4.00 5.62 2.47 3.44
Rural 6.48 9.60 3.56 5.45
Overall 6.24 9.22 3.42 5.20
2020-21 Urban 4.04 5.12 3.44 4.71
Rural 6.22 9.15 6.10 8.76
Overall 6.01 8.75 5.75 8.23
2021-22 Urban 4.15 5.63 3.55 5.03
Rural 6.10 8.69 6.36 9.46
Overall 5.91 8.38 5.99 8.87
2022-23 Urban 3.59 4.80 3.34 4.21
Rural 5.48 7.74 5.88 8.15
Overall 5.28 7.44 5.55 7.64
2023-24 Urban 2.94 3.77 2.25 2.78
(upto Rural 4.04 5.76 3.99 5.22
Sep 23 Overall 3.93 5.55 3.76 4.90
The DT damage rate ought to be analysed on the basis of total number of DTs damaged,
irrespective of the fact whether the transformer got damaged within warranty period or
otherwise, since all these DTs are part of the distribution system. The Commission has considered
it appropriate to reckon with the total DT damaged irrespective of damaged within warranty or
not. The high level of DT damage rate not only adversely affects continuity of supply but also
reflects upon poor monitoring and maintenance of distribution system which in turn also impacts
the finances of the distribution licensees.

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From analysis of the data reproduced in the above table, it is observed that failure rate of DTs in
urban and rural area of UHBVN and DHBVN during FY 2022-23 is 4.80 % & 7.74% and 4.21 % and
8.15 % respectively. These are more than the limit for both in urban and rural as prescribed by
the Commission in the Standard of Performance Regulations.
The Commission has considered the submissions of the petitioner(s) and observes that for FY
2022-23, overall transformer damage rate of both UHBVN and DHBVNL have improved
marginally as compared to the FY 2021-22, however, the DT damage rate in both the Utilities is
still much above the prescribed benchmark.

The Commission again directs the licensees to bring down the distribution transformer damage
rate below the prescribed limits in the FY 2024-25. Any slippage on account of the timeline
shall be construed as violation/ non-compliance of the Regulations/Orders of the Commission
and shall be dealt with in accordance with the provisions of the Act as well as the terms of
distribution licensee granted by the Commission.

As per the HERC MYT Regulations the distribution licensee shall maintain a proper record of
failure of the distribution transformers in rural and urban category and submit the same in the
quarterly report to the Commission and host the same on its website/portal on monthly basis
without any failure. The DISCOMs are again directed to ensure that quarterly reports be
submitted regularly without fail and to host the circle wise information of failure of the
distribution transformers in rural and urban category on its website regularly.

Non-replacement of Defective energy meters by the Distribution Licensees:

The DISCOMs, in their respective petitions for True up for FY 2022-23, APR for FY 2023-24 and
ARR for 2024-25 and subsequent submissions furnished the following details with respect to
defective energy meters as on 31.03.2023, progress of replacement of defective meters during
FY 2022-23 and defective meters existing as on 30.09.2023.
Defective Meters
(Status As on 31.03.2023)
Meter No. of defective meters (as on No. of defective meters (as No. of defective meters
category 31.03.2022) on 31.03.2023) replaced during 2022-23

Rural Urban Total Rural Urban Total Rural Urban Total

UHBVN
Single 58317 19998 78315 12605 7193 19798 65031 71703 136734
Phase

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Three 1771 2383 4154 406 776 1182 2169 7685 9854
Phase
Total 60088 22381 82469 13011 7969 20980 67200 79388 146588
DHBVNL
Single 56829 4805 61634 52515 4803 57318 65343 48679 114022
Phase
Three 66381 1472 67853 587 1099 1686 4535 9977 14512
Phase
Total 1,23,210 6,277 1,29,487 53102 5902 59004 69878 58656 128534
Grand 183298 28658 211956 66113 13871 79984 137078 138044 275122
Total

Status as on 30.09.2023
Meter No. of defective meters No. of defective meters No. of defective meters
category (as on 31.03.2023) (as on 30.09.2023) replaced during 4/2023 to
09/2023
Rural Urban Total Rural Urban Total Rural Urban Total
UHBVN
Single Phase 12605 7193 19798 13566 7806 21372 21940 14026 35966
Three Phase 406 776 1182 798 1145 1943 899 1838 2737
Total 13011 7969 20980 14364 8951 23315 22839 15864 38703
DHBVNL
Single Phase 52515 4803 57318 49341 4535 53876 32755 22537 55292
Three Phase 587 1099 1686 527 997 1524 1108 6506 7614
Total 53102 5902 59004 49868 5532 55400 33863 29043 62906
Grand Total 66113 13871 79984 64232 14483 78715 56702 44907 101609
The Commission observes that the total number of defective meters as on 31.03.2023 in both
DISCOMs were 79,984 (20,980 in UHBVNL and 59,004 in DHBVNL) after replacement of 2,75,122
defective meters (1,46,588 by UHBVNL & 1,28,534 by DHBVNL) during FY 2022-23. As on
30.09.2023, 1,01,609 meters are still defective (38,703 in UHBVNL and 62,906 in DHBVNL).
The Commission observes that, despite replacement of defective meters during the period from
31.03.2023 to 30.09.2023, the defective meters count in DHBVNL, as on 30.09.2023, is quite high.
This is a matter of great concern and bound to reflect on financial health of the Distribution
Licensee besides adversely affecting consumer satisfaction.

DHBVN is directed to clear the backlog of defective meters and to ensure that at no point of
time the percentage of defective meters exceeds 2% limit as per SOP regulations in vogue.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

6.5 Non-replacement of Electro-mechanical Meters

The Commission, in tariff order dated 15/02/2023, had directed the DISCOMs especially DHBVN
to replace all electromechanical meters shown pending for replacement and to submit
compliance report within 3 months from date of order.
DISCOMs have submitted the progress of electromechanical meters’ replacement (except AP)
along with its latest status as on 30.09.2023 as under:
Meter No. of Electromechanical No. of Electromechanical No. of Electromechanical
category meters replaced during meters as on pending for replacement as
on 30.09.2023
FY 2022-23 31.03.2023 (ending Sept. ‘23)
Rural Urban Total Rural Urban Total Rural Urban Total
UHBVN
Single Phase 26315 22441 48756 17165 0 17165 15493 0 15493
Three Phase 122 1799 1921 0 0 0 0 0 0
Total 26437 24240 50677 17165 0 17165 15493 0 15493
DHB VNL
Single Phase 13664 0 13664 44774 0 44774 38949 0 38949
Three Phase 0 0 0 0 0 0 0 0 0
Total 13664 0 13664 44774 0 44774 38949 0 38949
Grand Total 40101 24240 64341 61939 0 61939 54442 0 54442

The Commission observes that out of total electromechanical meters of 61,939 (17,165 in
UHBVN and 44,774 in DHBVN) existing as on 31.03.2023, 54442 electromechanical meters (i.e.
15493 in UHBVN and 38949 in DHBVN) are yet to be replaced as on 30.09.2023.
The pace of replacement of electromechanical meters has slowed down in both the DISCOMs as
only 1672 & 5825 electromechanical meters have been replaced in UHBVN & DHBVN
respectively, in first six months of FY 2023-24.

The Commission directs DISCOMs to ensure replacement of all electromechanical meters within
one month and submit compliance report immediately thereafter.

6.6 Implementation of Smart metering Projects in Haryana

The Commission, vide Tariff Order dated 15.02.2023, had directed the DISCOMs to expedite the
Implementation of Smart Metering Project already undertaken to ensure the competition of
project within the time lines of agreement executed between EESL and DISCOMs.
DISCOMs have reported installation of 8.19 Lakhs meters (UHBVN 4.71 Lakhs, DHBVN 3.48 Lakhs)
up to December, 2023 against a total of 10 lakh meters which indicates a very slow progress.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Further the DISCOMs have submitted the progress of the project for installation Prepaid Smart
Meter Installation in remaining areas of Haryana, as under:

Smart Metering under RDSS- Now planned with Discom’s own funding & approach

The sanction of smart metering works under RDSS has been withdrawn by MoP/GoI upon state
request to implement the works with Capex/Hybrid mode through its own funding subject to
adherence to timelines for completion prescribed under the scheme.
The installation of smart meters shall be taken up in two Phases (5 packages in UHBVN and 4
packages in DHBVN). Phase-wise number of smart meters to be installed with target date of
completion of project is as under: -

UHBVN

Phase-I : 1470554 Meters, Target to complete by Dec 2025

Phase-II : 1215640 Meters, Target to complete by Dec 2026

DHBVN

Phase-I : 1394494 Meters, Target to complete by Dec 2025

Phase-II : 1895857 Meters, Target to complete by Dec 2026

In view of importance of Smart Metering Projects, DHBVN is directed to expedite the
Installation of Smart Metering Project already undertaken with EESL as installation of about
1.52lakh meters out of 5lakh meters is still pending.
Further the DISCOMs are advised to adhere to the timelines for the metering project for which
the tenders have been floated by both DISCOMs so that the Phase-I & Phase-II of the projects
are completed by Dec.25 & Dec.26 respectively.

6.7 Pending electricity connection / load

The DISCOMs, in their petition for true up of FY 2022-23, Annual Performance Review for FY
2023-24 and Annual Revenue Requirement for FY2024-25 and subsequent submissions in the
matter have furnished information regarding pending applications for release of connection
(non-AP), as under:

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

a) DHBVN:

Category Wise Status of Pending Applications for FY 2023-24

Category Pending as on New Application Disposed of During Pending as on
31.03.2023 received 2023-24 2023-24 30.09.2023
No. of Load No. of Load No. of Load No. of Load
Appli- (KW) Appli- (KW) Appli- (KW) Appli- (KW)
cation cation cation cation
Bulk Domestic Supply 34 46927 102 188922 68 116154 68 119695
Bulk Supply 4 8596 29 53826 24 41361 9 21061
Domestic (DS) 10342 49065 131726 540182 139994 577722 2074 11526
ECS 25 6247 234 35014 233 33012 26 8249
FPO 68 842 381 3478 429 4107 20 213
HT Industry 176 227008 556 218403 604 217422 128 227989
Hording or Decorative Light 0 0 5 35 5 35 0 0
Lift Irrigation 13 235 1077 21305 1052 21000 38 540
LT Industry 301 7122 2577 51476 2762 55766 116 2832
Non-Domestic (NDS) 2531 108710 30074 553688 31934 494748 671 167649
Public Water Work 187 8150 1265 52915 1222 48333 230 12732
Railway Traction 0 0 8 102200 7 75200 1 27000
Saubhagya 108 152 1141 1513 1238 1650 11 15
Street Light 48 1096 322 3726 343 4291 27 531
Grand Total 13837 464149 169497 1826682 179915 1690801 3419 600031

As per the latest status of pending connections in DHBVNL, as on 30.09.2023, a total 3419
applications (with applied load of 600.031 MW) have been shown as pending for release out of
which 128 applications (with applied load of 227.989 MW) are under the HT Supply category
alone.

b) UHBVN:

Category Wise Status of Pending Applications for FY 2023-24

New Application Disposed off During Pending Applications
Pending at
Received 2023-24 2023-24 as on 30.09.2023
31.03.2023
(Apr-23 to Sep-23) (Apr-23 to Sep-23) Total Pending
Category
No. of No. of No. of No. of
Load (in Load (in Load (in Load (in
Appli- Appli- Appli- Applicatio
KW) KW) KW) KW)
cation cation cation n
Bulk Domestic
1 107 3 1521 0 0 4 1628
Supply
Bulk Supply 5 1124.5 2 399 6 1307.5 1 216
Domestic 7088 13438.1 51417 100708.4 50822 98961.5 7683 15185
288147.
HT Industry 223 440 429383.1 382 110117.9 281 607412.3
1
Hording or
0 0 0 0 0 0 0 0
Decorative Light
Lift Irrigation 5 409.6 1117 22322.5 1066 18115.6 56 4616.5
LT Industry 203 4898.9 923 20446.4 961 21629.3 165 3716
Non-Domestic 1780 25925.7 13489 63565 13384 62952.9 1885 26537.8
Public Water
55 2572 263 7655.2 245 6127.6 73 4099.6
Works

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Railway Traction 0 0 1 5000 0 0 1 5000

Saubhagya 855 1122 5337 7136.8 5333 7112.7 859 1146.1
Street Light 55 174 229 1320.6 245 1252 39 242.6
DMRC 0 0 0 0 0 0 0 0
FPO 8 110.9 78 820.3 71 802.9 15 128.3
ECS 5 670 24 5743.9 22 1200.9 7 5213
338699.
Total 10283 73323 666022.2 72537 329580.8 11069 675141.2
8
*Out of 138 MW overdue pending load, 2 no applications - IOCL has a load 70 MW and Air Liquid
has a load 35 MW.
As per the latest status of pending connections in UHBVN, as on 30.09.2023, a total 11069
applications (with applied load of 675.141MW) have been shown pending wherein out of which
applications (with applied load of 607.412 MW) are under HT Supply category alone.
The Commission observes that although UHBVN has released a total load of 329.580 MW against
total number application of 73,606 under various categories from 01.04.2023 to 30.09.2023, yet
load of 675.141MW is still pending for release.
DHBVN has released total load of 1690.801 MW against total number application of 1,83,334
under various categories from 01.04.2023 to 30.09.2023, however still a total load of
600.031MW is still pending for release as on 01.10.2023.
In view of the above, the total pending load for release as on 30.09.23 works out to 1,275.172
MW which was 802.848MW as on 01.04.2023.
The Commission has taken a serious note of the fact that there are pending applications for new
connection and load enhancement adding up to substantial cumulative load. Timely release of
pending connections will result in consumer satisfaction besides augmentation of revenue from
Sale of Power for the DISCOMs.
The DISCOMs are directed to make all out efforts to release all pending connections within the
time frame as specified in various law/regulations in-vogue and submit a status report
regarding release of Non-AP connections / loads, within three months.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 7
WHEELING CHARGES

7.1 Wheeling Charges

At the onset the Commission observes that segregated accounts including voltage wise assets
and losses for the distribution and retail supply business are a pre-requisite for determination of
wheeling charges and cross-subsidy surcharge. The petitioner(s) have not estimated / projected
wheeling charges to be recovered from the beneficiaries of its distribution system. Further, till
the time ‘carriage’ and ‘content’ businesses are spun off as separate businesses the segregated
costs would largely be based on assumptions only. Accordingly, the average rate of 6.06%
(average of DH & UH distribution business) of the annual revenue requirement may be
considered for estimating the “network establishment and operation cost” as distinct from retail
supply for the upcoming year i.e. 2024-25. Hence, for the purpose of working out wheeling
charges for the FY 2024-25, the cost allocation has been taken as 6.06%, on the basis of
segregated accounts provided by the Discoms.

The calculations and the methodology, in line with the previous year order, is presented in the
table that follows:
HERC appoved Wheeling Charges (FY 2024-25)
1 Network expenses (per kWh)
a. Network establishment and operation cost (6.06% of the net ARR) (Rs. Million) 26823.54
Allowed gross volume of power purchase by the Discoms at Discom Periphery
b. 68,079.81
(MUs) excluding inter-state sales.
c. Expenses (Rs / kWh) (a/b) 0.39
2.1 Cost of losses in the system HT
a Approved Energy available for sale to Discoms (MU) 68,079.81
b Distribution system losses (HT) (technical) % 4.09%
c Losses (MU) (2.1a X 2.1b) Million Units 2782.691
d Bulk supply power purchase rate for the Discoms (Rs. / kWh) 5.34
e Total cost of losses (2.1dx2.1c) Rs. million 14864.16
f Cost per unit of losses (Rs. /unit) (2.1e/1b) 0.22
2.2 Cost of losses in the system LT
a Approved Energy available for sale to Discoms (MU) 68,079.81
b Distribution system losses (technical) % 10.18%
c Losses (MU) (2.2a X 2.2b)) 6933.60
d Bulk supply power purchase rate for the Discoms (Rs. / kWh) 5.34
e Total cost of losses (2.2dx2.2c) Rs. million 37036.84
f Cost per unit of losses (Rs. /unit) (2.2 e/1b) 0.54
3.1 Wheeling Charges HT (Rs. / kWh) (1c+2.1f) rounded off 0.61
3.2 Wheeling Charges LT (Rs. / kWh) (1c+2.2f) rounded off 0.94

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

7.2 Cross-Subsidy Surcharge (CSS)

The regulation 63 of the HERC MYT Regulations, 2019 provides that the cross-subsidy surcharge
shall be payable by all intra-State open access consumers, except those persons who have
established captive generating station, and are availing open access for carrying the electricity to
a destination for their own use.
The Cross-subsidy surcharge, as quantified by the Commission, shall also be payable by such open
access consumer(s) who receives supply of electricity from a person other than the distribution
licensee in whose area of supply he is located, irrespective of whether he avails such supply
through transmission/distribution network of the licensee or not. The consumers located in the
area of supply of a distribution licensee but availing Open Access exclusively on inter-State
transmission system shall also pay the cross-subsidy surcharge as determined by the
Commission.
Further, Section 42 of the Electricity Act, 2003 provides that the surcharge and the cross-
subsidies shall be progressively reduced. The Commission has worked out CSS in line with the
formula provided in the National Tariff Policy, 2016. The National Tariff Policy dated 28.01.2016
provides as under: -
“SERCs may calculate the cost of supply of electricity by the distribution licensee to
consumers of the applicable class as aggregate of (a) per unit weighted average cost of
power purchase including meeting the Renewable Purchase Obligation; (b) transmission
and distribution losses applicable to the relevant voltage level and commercial losses
allowed by the SERC; (c) transmission, distribution and wheeling charges up to the
relevant voltage level; and (d) per unit cost of carrying regulatory assets, if applicable”.
The above is subject to the proviso that the surcharge shall not exceed 20% of the CoS applicable
to the category of the consumers seeking open access. The Commission has considered the
methodology prescribed by the National Tariff Policy dated 28.01.2016, while working out cross-
subsidy surcharge in the present Order. The relevant provision of the NTP is reproduced below:
“Surcharge formula:

S= T – [C/ (1-L/100) + D+ R]

Where

S is the surcharge

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

T is the tariff payable by the relevant category of consumers, including reflecting the Renewable
Purchase Obligation.

C is the per unit weighted average cost of power purchase by the Licensee, including meeting the
Renewable Purchase Obligation.

D is the aggregate of transmission, distribution and wheeling charge applicable to the relevant
voltage level.
L is the aggregate of transmission, distribution and commercial losses, expressed as a percentage
applicable to the relevant voltage level.
R is the per unit cost of carrying regulatory assets (emphasis added).
The above formula may not work for all distribution licensees, particularly for those having
power deficit (emphasis added), the State Regulatory Commissions, while keeping the overall
objectives of the Electricity Act in view, may review and vary the same taking into consideration
the different circumstances prevailing in the area of distribution licensee.
Provided that the surcharge shall not exceed 20% (emphasis added) of the tariff applicable to
the category of the consumers seeking open access.
Provided further that the Appropriate Commission, in consultation with the Appropriate
Government, shall exempt levy of cross subsidy charge on the Railways, as defined in Indian
Railways Act, 1989 being a deemed licensee, on electricity purchased for its own consumption.
No surcharge would be required to be paid in terms of sub-section (2) of Section 42 of the Act
on the electricity being sold by the generating companies with consent of the competent
government under Section 43 (A) (1) (c) of the Electricity Act, 1948 (now repealed) and on the
electricity being supplied by the distribution licensee on the authorization by the State
Government under Section 27 of the Indian Electricity Act, 1910 (now repealed), till the current
validity of such consent or authorization.
The surcharge may be collected either by the distribution licensee, the transmission licensee, the
STU or the CTU, depending on whose facilities are used by the consumer for availing electricity
supplies. In all cases the amounts collected from a particular consumer should be given to the
distribution licensee in whose area the consumer is located. In case of two licensees supplying in
the same area, the licensee from whom the consumer was availing supply shall be paid the
amounts collected”. The Commission has, estimated cost of service based on the above formula,
relying on the indicative voltage wise losses submitted by the two licensees.
UHBVNL:

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

UHBVNL provided the details as part of additional information vide letter No. Ch-82/RA/F-
25/Vol-84 dated 11.01.2024 as below:
Voltage level and losses Loss %age
33 kV Line Losses 0.28%
33 kV Transformer Losses 0.49%
11 kV Line Losses 2.69%
11 KV Transformer Losses 1.08%
LT Line Losses 4.43%
Total 8.98%

For the purpose of working out the CoS (HT, LT), the category wise estimated losses are as
follows: -
FY 2024-25
UH
Combined T&C Losses at Distribution level
HT 7.74%
LT 12.79%
Total 10.75%

Based on the above, UHBVN submitted the Consumer category wise COS as follows:
FY 2024-25
UHBVN
A Power purchase cost (Rs Crores)
1 PP Cost 12,293.34
2 Revenue from ISTS Sales -
3 Net PP Cost 12,293.34
4 ISTS Charges 957.72
5 Total PP Cost 13,251.06
6 Intra Transmission Charges 967.42
7 Distribution Charges 3,115.15
B Power purchase units (MU)
8 Available Power 29,317.33
9 Less: Intrastate Purchase 5,374.39
10 Inter-state Power Purchase 23,942.94
11 Less: Interstate Trans Losses 3.62%
12 PP Qty @ State Boundary 28,449.44
13 Less: Intrastate Trans Losses 2.05%
14 PP Qty @ Discom Boundary 27,866.23
15 Energy Sold to consumers 24,870.61
C Elements of cost of service
Per Unit Weighted average cost of power per unit at Discom periphery (Total
(C)14 4.76
Gen - Interstate Sale) (5/12)
Distribution (net of power purchase cost) and Wheeling cost at consumers
(D)15 1.25
end (Rs./kWh) (7/15)
Intrastate Transmission cost at consumers end (Rs./kWh) (Transmission and
(R) 16 0.39
SLDC cost/ sales) (6/15)

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Aggregate of transmission, distribution, and commercial losses applicable to

17
the relevant voltage level
(L) i HT 7.74%
(L) ii LT 12.79%
iii Total 10.75%
18 Cos (C/(1-L/100) +D+R)
i HT 6.81
ii LT 7.08
iii Total 6.97

As per the trend of past few years, UHBVNL has submitted that the Nigam is trying to reduce the
cross subsidy through efficient power purchase and reduction in AT&C loss, which in turn will
reduce the CoS. Accordingly, the actions will eventually decrease the cost of supply to different
category of consumers. However, the same is a long-term process.
DHBVNL
DHBVNL provided the additional information regarding voltage wise losses vide letter No. Ch-
110/SE/RA-772 dated 18.12.2024 for working out CoS (HT, LT).
Voltage level and losses Loss %age
33 kV Line Losses 0.36%
33 kV Transformer Losses 0.20%
11 kV Line Losses 3.99%
11 KV Transformer Losses 0.59%
LT Line Losses 6.30%
Total 11.07%

The voltage wise technical losses filed by the Discoms as part of the additional information has
been briefed as under: -
Voltage Wise Loss Estimation (as filed by the Discoms)
UHBVNL up to 31.03.2023 DHBVNL up to 31.03.2023
Voltage Levels % %
33 kV Line Losses 0.28% 0.36%
33 kV Transformer Losses 0.49% 0.20%
11 kV Line Losses 2.69% 3.99%
11 KV Transformer Losses 1.08% 0.59%
LT Line Losses 4.43% 6.30%
Total at LT level 8.98% 11.07%
The Commission observes that the voltage wise losses are never submitted by the Licensees
along with the main petition. They do so in compliance with the deficiency letter issued by the
Commission.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

In line with the National Tariff Policy, the Commission has calculated the voltage wise CoS and
Cross Subsidy Surcharge. The difference between technical losses so determined and actual total
distribution system losses are considered to be on account of reasons other than technical losses
and are therefore taken as commercial losses. The commercial losses so determined have been
apportioned between HT and LT voltage levels in proportion to annual gross energy sales at these
voltage levels. The annual gross energy sales at the given voltage levels has been taken as the
sum of energy consumption of all consumer categories connected at that voltage plus the
technical distribution losses corresponding to that voltage level as worked out in the voltage wise
loss calculations as per the details provided in the table below: -
Calculation of Voltage wise losses for the FY 2024-25
UHBVNL DHBVNL Total
1a HT sales 11,001.72 14,920.81 25,922.54
1b LT sales 14,976.75 20,372.55 35,349.30
1 Total Sales 25,978.47 35,293.36 61271.84
2 Losses %
2a HT 3.46% 4.55%
2b LT 8.98% 11.07%
3 Loss units
3a HT 380.66 678.90 1059.56
3b LT 1344.91 2255.24 3600.15
Total loss units 1725.57 2934.14 4659.71
Sales grossed up by Technical losses
4
(1+3)
4a HT 11382.38 15599.71 26982.09
4b LT 16,321.66 22,627.79 38949.45
Total Gross Sales 27,704.04 38,227.50 65,931.55
5 Combined Technical losses
5a HT (3a/1a) 4.09%
5b. LT (3b/1b) 10.18%
5 Total 7.60%
6 Total Distribution Losses 2597.85 3529.34 6127.18
7 Total Commercial losses (6-3) 872.28 595.20 1467.47
Commercial losses allocated to HT
8
and LT based on grossed up units (4)
8a HT 358.38 242.89 600.55
8b LT 513.90 352.31 866.92
Total Voltage level distribution
9
losses (3+8)
9a HT 739.04 921.78 1660.11

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

UHBVNL DHBVNL Total

9b LT 1858.81 2607.55 4467.07
6127.18
Combined Technical and
10 Commercial losses at Distribution
level
10a HT 6.40%
10b LT 12.64%

In line with the voltage wise (HT and LT Voltages) the distribution losses as worked out above,
the calculations for CSS as per National Tariff Policy formula for the FY 2024-25 is as under:
Cost of Service for FY 2024-25
Cost of Service as per National Tariff Policy 2024-25
Elements of cost of service
1 Per Unit Weighted average cost of power at State/ Discom periphery (Paisa/kWh) 470.13
Aggregate of transmission, distribution and wheeling charges applicable to the
2 relevant voltage level
Intrastate Transmission cost at consumers end (Paise/kWh) (Transmission and SLDC
32.96
cost/ sales) Paisa / kWh
Distribution (net of power purchase cost) and Wheeling cost at consumers end
76.74
(Paise/kWh)
Aggregate of transmission distribution and commercial losses applicable to the
3 relevant voltage level (%)
HT 6.40%
LT 12.64%
4 Cost of Service
C/(1-L/100)+D+R
HT (Paise / kWh) 612.00
LT (Paise / kWh) 647.84
Average CoS 629.92

The above loss allocation is reflected in the energy allocators at HT and LT voltage levels i.e. lower
cost attributed to the HT consumers and higher cost attributed to the LT Consumers. Thus, the
Cost of Service in the case of HT Consumers is comparatively lower than that of the consumers
receiving electricity supply at LT voltage. The CSS has been worked out as the difference between
the applicable tariff and voltage wise CoS computed as above. The Cross-subsidy surcharge for
the FY 2024-25, as per the NTP formula, shall be as per the table that follows: -

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Cross-subsidy surcharge for FY 2024-25 (Rs/kWh)

CoS Tariff (FC Cross Subsidy CSS Limited
(Rs./kWh) + EC) Surcharge to 20% as
(Rs./kWh) (Rs./kWh) per NTP
1 2 3= 2-1
1 HT Supply 6.12 7.59 1.47 1.22
2 Bulk Supply (other than DS) 6.12 7.38 1.26 1.22
3 LT Supply 6.48 7.63 1.15 1.15

The applicable CSS has been restricted to 20% (+/-) limit in accordance with the National Tariff
Policy.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

CHAPTER 8
RENEWABLE PURCHASE OBLIGATION (RPO)
Section 61 (h) read with Section 86 (1) (e) of the Electricity Act, 2003 cast statutory obligation on
the Commission to promote cogeneration and generation of electricity from renewable sources
of energy by providing suitable measures for connectivity with the grid and sale of electricity to
any person, and also specify, a percentage of the total consumption of electricity in the area of
distribution licensee, for mandatory purchase of electricity from such sources.
In pursuance to the above statute, the Commission notified the Haryana Electricity Regulatory
Commission (Terms and Conditions for determination of Tariff from Renewable Energy Sources,
Renewable Purchase Obligation and Renewable Energy Certificate) Regulations, 2021 (2 nd
Amendment), 2022, on 03.01.2023, pursuant to the RPO trajectory notified by the Ministry of
Power on 22.07.2022. Regulation 62 of the ibid Regulations, has specified the RPO obligation, as
under: -
Year Wind RPO HPO Other RPO Total RPO
2023-24 1.60% 0.66% 24.81% 27.08%
2024-25 2.46% 1.08% 26.37% 29.91%
2025-26 3.36% 1.48% 28.17% 33.01%
2026-27 4.29% 1.80% 29.86% 35.95%
2027-28 5.23% 2.15% 31.43% 38.81%
2028-29 6.16% 2.51% 32.69% 41.36%
2029-30 6.94% 2.82% 33.57% 43.33%
(a) Wind RPO shall be met only by energy produced from Wind Power Projects (WPPs),
commissioned after 31st March 2022. Further, Wind RPO may also be met from the
wind energy consumed over and above 7% of the total energy consumption, from
WPPs commissioned till 31.03.2022.
(b) Hydro power Purchase Obligation (HPO) are to be met from Large (LHPs) or Small
Hydro Power Projects (SHPs) including Pumped Storage Projects (PSPs),
commissioned after 8th March 2019.
(c) Other RPO may be met by energy produced from any RE power project not
mentioned in (a) and (b) above.
Additionally, the following percentage of total energy consumed, excluding consumption met
from RE sources and hydro sources, was specified for the renewable energy along with/through
storage, including pumped storage projects (PSPs) having capacity more than 25 MW:

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F.Y. Storage (on Energy basis)

2023-24 1.0%
2024-25 1.5%
2025-26 2.0%
2026-27 2.5%
2027-28 3.0%
2028-29 3.5%
2029-30 4.0%

In compliance of RPO targets set by the Commission for the FY 2022-23, the Discoms have filed
their compliance report, vide letter no. Ch-197/CE/HPPC/LTP-III/T-27/Vol-II dated 01.05.2023, as
under: -
Particulars FY 2022-23
Approved Energy availability for sale to DISCOMS (in MUs) for FY 1 46261
2022-23 as per HERC ARR Order dated 30.03.2022
Power procured from Hydro and Renewable sources (in MUs) for FY 2 7531
2022-23
Energy consumption at DISCOMs periphery 3=1-2 38730
RPO Required under category "other RPO" (in %) 4 23.44
RPO required under category "WPO" (in %) 5 0.81
RPO Required under category "HPO" (in %) 6 0.35
RPO target required "other RPO" (MUs) 7=3*4/100 9078
RPO target required "wind RPO" (MUs) 8=3*5/100 314
RPO target required "HPO" (MUs) 9=3*6/100 136
No. of MUs generated/purchased from Renewable energy sources in 10 15319
"other RPO- category
No. of MUs generated/purchased from Renewable energy sources in 11 323
"WPO" category
No. of MUs generated/purchased from Renewable energy sources in 12 581
"HPO" category
Shortfall (-)/Surplus (+) (other RPO) 13=10-7 +6241
Shortfall (-) /Surplus (+) (WPO) 14=11-8 +9
Shortfall (-) Surplus (+) (HPO) 15=12-9 +445

The Commission observes that the Discoms had applied for issuance of REC for the procurement
of renewable energy over and above the target set by the Commission, for the FY 2022-23, even
after offsetting the shortfall of 2505 Mus in compliance of ‘other RPO category’ for the FY 2021-
22. Discoms got the data validated from SLDC and some of the values got re-stated. Accordingly,
certificates were issued to UHBVNL and DHVBNL regarding their eligibility for issuance of RECs,
in respect of surplus in ‘wind RPO’, ‘HPO’ and ‘other RPO’ is 2918 Mus, 446 MUs and 4059 MUs.

HAREDA is obligated to monitor and report compliance by other obligated entities as well. In this
regard, the Commission had also directed HAREDA, vide memo no. 1577/HERC/Tariff dated
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04.07.2023, to proceed in line with regulation 65 “Effect of Default’ of the HERC RE Regulations
in vogue, against the defaulting obligated entities including the CPP of 5 MW and above and open
access consumers. HAREDA was further directed to sensitize the consumers and the obligated
entities, the need to contribute towards greening the power sector.

In accordance with the provisions of the HERC RE Regulations in vogue, the RPO for the FY 2024-
25 is 29.91% of the total energy consumption of the Discoms. The approved RPO for the FY 2024-
25 is as under: -
Energy %age of Wind Wind %age of HPO HPO Other Other Total Energy Energy
Consumption RPO of energy RPO of energy (MU) RPO RPO renewable Storage Storage
for 2024-25 Consumption (MU) Consumption as (MU) energy (MU)
(MU) %age required to
of be
energ purchased
y sales (MU)
26.37 1.5% 767
51128 2.46% 1257 1.08% 552 13482 15291
%
* Energy available for sale by DISCOMs has been taken net of intra-state transmission losses, excluding
energy purchased from RE sources and Hydro.

The volume of energy to be purchased from renewable energy sources as per above table is the
total RPO of the Discoms for the FY 2024-25. DISCOMs are advised to ensure that the Solar RPO
data provided by them to HAREDA includes energy generated by Rooftop solar system also.

The State Nodal Agency i.e. HAREDA shall continue submitting quarterly status of RPO met by
the obligated entities for the last quarter, separately for Wind RPO, HPO, other RPO and energy
storage, in accordance with the provisions of regulations 64 (3) of the Haryana Electricity
Regulatory Commission (Terms and Conditions for determination of Tariff from Renewable
Energy Sources, Renewable Purchase Obligation and Renewable Energy Certificate) Regulations,
2021.

The Discoms and other obligated entities are directed to provide requisite information to the
State Agency on monthly basis by 10th of every month for the previous month to enable the
State Agency to submit quarterly report to the Commission.

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CHAPTER 9
ADDITIONAL TARIFF ISSUES
UHBVNL, in its petition, in addition to the True up of FY 2022-23, APR of FY 2023-24 and ARR for
FY 2024-25, has submitted few additional issues/clarifications that may require consideration
from the Hon’ble Commission. UHBVNL has prayed to the Hon’ble Commission to peruse and
consider the following issues for ease of implementation of tariff order.

9.1 Tariff of Bulk Supply (Domestic) Category

The Hon’ble Commission in its Tariff order dated 15.02.2023 for FY 2023-24 determined the tariff
for Bulk Supply (Domestic) Category as below:
Tariff for 2023-24 (w.e.f. 01.04.2023)
Category of consumers Energy Fixed Charge (Rs. per kW per MMC (Rs. per
Charges month of the connected load / kW per month
(Paisa / kWh per kVA of sanctioned contract of the connected
or/ kVAh) demand (in case supply is on HT) load or part
or as indicated thereof)
Bulk Supply (Domestic) Category
For Total Consumption in 525/ kWh Rs. 80/kW/ month of the
month not exceeding 800 recorded demand
units/ flat/ dwelling units
(DU)
For Total Consumption in 620/ kWh Rs. 80/kW/ month of the
month exceeding 800 units/ recorded demand
flat/ dwelling units (DU)

In order to implement this tariff, DISCOM require regular monthly updates from the respective
consumer of BDS category about the occupancy of Flats/dwellings as also provided in HERC Single
Point Supply Regulation, 2020, as under: -
“Clause 6.7
The Employer /GHS shall update the occupancy status (nos. of flats/dwellings occupied
as on each billing date) in writing to the licensee for proper billing to avoid any wrong
application of tariff for Single Point Supply.”

As the DISCOMs have to rely on declarations provided by Bulk Supply Consumers regarding
occupancy of flats, hence, there are chances of inaccurate assessment of applicable tariff, as
these consumers might take advantage of the situation and may deliberately provide inaccurate
information to fall under low tariff sub-category.

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It would be appropriate if the Hon’ble Commission considers defining only one slab tariff for BDS
category where there is no requirement of obtaining regular monthly occupancy data from the
consumers and all the consumers could be billed accurately without any challenge. This shall
streamline the implementation of the same in field offices to great extent.
Commission Observations:
The Commission has considered the submissions. However, in the absence of any data on the
likely revenue impact and the fact that it may not be appropriate to club small and medium to
large consumers under a single tariff as well as the fact that individual DS consumers are also
given the slab benefit for lower consumption, the Commission is not considering the proposal
of the Nigam on this issue. Moreover, there should be any difficulty in implanting the tariff as
it exists if the field officers are vigilant and careful in discharging their duty.

9.2 Incorporation of Tariff Clarification given by HERC vide Order dated 18.07.2023.
It is submitted that some important clarifications were notified by the Commission which are very
essential for implementation of Tariff. The same are reproduced as under: -
(a) Assessment of Fixed Charges for erstwhile NDS category (above 50kW) and existing
consumers having sanctioned load above 50W and upto 70 KW (on LT Supply)
The Hon’ble Commission has clarified that in the absence of declared contract demand, the
sanctioned load of such consumers available with the Discoms be considered for levy of Fixed
Charges.
(b) Charging of LT Supply Tariff
The Hon’ble Commission has also clarified that LT supply consumers (having sanctioned load up
to 20 KW) shall be billed only on kVAh tariff with the exception of billing in kWh only when the
installed meter at consumer premises is not kVAh compliant.
The Hon’ble Commission is requested to consider incorporating these clarifications in the Notes
to the proposed ‘Schedule of Tariff’ for FY 2024-25.
Commission Observations: The submissions have been noted. However, the Discoms should
make earnest endeavour for early replacement of meters not having kVArh register.

9.3 ToD/ToU/Night Time Concessional Tariff

In the Tariff Order dated 15.02.2023, Hon’ble Commission has approved the ToD/ToU/Night Time
Concessional Tariff with the time duration i.e., 2100 hrs to 0530 hrs. In this regard, the Hon’ble

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Commission is humbly requested to authorize DISCOMs to decide the time duration during which
Night Time Concessional Tariff can be offered based upon the power availability/power
Procurement Scenario.
Commission Observations:
The Commission has considered the submissions and observes that the Discoms may
implement concessional tariff as per availability of surplus power in a particular time slot after
giving it a wide publicity provided there is a provision in the installed meter and the data is
downloadable to avoid disputes.

9.4 Cash Acceptance Limit for Theft Penalty and Surcharge Waiver Cases.
The Hon'ble commission vide point 14 of the Notes to Schedule of Tariff and Charges of Tariff
order dated 15.02.2023 for FY 2023-24 provided for cash acceptance limit as below:
"It is clarified that the acceptance limit of cash will be Rs 5000 (five thousand)
However, the cash collection limit for theft penalty amount may be enhanced to Rs.
2,00,000 (two lakh); submission of PAN Card shall be mandatory for any transaction
exceeding Rs. 50,000 (fifty Thousand). It is further made clear that the AEE/ SDO
concerned shall be fully responsible for cash collected and prompt remittance into
the designated bank(s)."
The issue of requirement of PAN card for transaction exceeding Rs. 50,000 was deliberated upon
by the Nigam and UHBVN’s Tax Consultant M/s S. Methani & Co. was approached for advice. The
Tax Consultant advised that examination of Income Tax Rules, 1962 reveals that there is no
requirement of obtaining PAN/ declaration in Form No. 60 in case of receipt of cash in excess of
Rs 50,000 and above from electricity consumers, as under:
"The matter has been examined by us with reference to the provisions of Income Tax
Law. In the matter, reference is drawn to Rule 114 C of the Income Tax Rules, 1962,
which governs the issue relating to verification of PAN declaration in Form No 60 in
respect of the transactions specified in file 114 B of the Income Tax Rules, 1962.
Examination of these rules were reveals that there is no requirement of obtaining PAN/
declaration in Form No. 60 in case of receipt of cash in excess of Rs 50,000 and above
from electricity consumers. Thus, the corporation can accept cash in excess of Rs 50,000
without obtaining PAN/declaration in Form No. 60 (in non-PAN cases). However, it may
be pertinent to bring out here that the Corporation cannot accept more than Rs. 2(two)

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lakh in cash from a single person in a day or against same transaction/event as the
same will attract penalty of sum equal to the amount of such receipt under the
provisions of section 271D of the Income-tax Act, 1961."In light of above facts, the
Nigam humbly submits the proposal of dispensing with the condition of obtaining PAN
number of concerned consumers in case of deposit of cash exceeding Rs. 50,000 up to
Rs. 2 lakhs in "Theft Penalty and Surcharge Waiver Cases" only.
Pursuant to the advice and provisions of Income-tax Act, 1961, UHBVN has already requested
HERC for reconsidering the above note in the review petition filed by UHBVN for review of
ARR/Tariff Order dated 15.02.2023.
This petition was decided vide final order dated 18.07.2023, however, this issue was remained
undecided. UHBVNL has prayed to the Commission to amend the note by keeping in view the
advice of Tax Consultant.
The issues as proposed above are submitted for perusal of the Hon’ble Commission, so that they
may be made part of ARR/Tariff Order for FY 2024-25.
Commission Observations:
The Commission has considered the ibid submissions and observes that it should be the
endeavour all stakeholders to discourage use of ‘cash’ as far as possible. If at all ‘cash’
transactions cannot be avoided it should be done with complete transparency. Hence, the
dispensation in place need no change especially keeping in view the reports of frauds /
embezzlements by the Discoms employees / collecting agencies in cash receipts.

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CHAPTER 10
TIME OF DAY/USE TARIFF

10.1 ToD / ToU Tariff / Night-time Concessional Tariff for FY 2024-25

The Commission had introduced ToD tariff vide ARR/Tariff Order dated 30.03.2022 and further
certain amendments were introduced vide order dated 15.02.2023. In amendment of the same,
the Commission for the FY 2024-25 approves the ToD on the following terms and conditions to
encourage consumption of power during off peak period(s). Such dispensation shall be a win-win
situation for both the distribution licensee(s) as well as the electricity consumers of the Haryana.
The former would benefit in terms of saving of additional power purchase cost during the peak
months / hours as well as incurring cost on augmentation of transmission / distribution and
wheeling network. While the latter will benefit in terms of reduction in energy bills by shifting
their demand to off peak periods. Hence, the Commission has dispensed with public proceedings
on the ToD / ToU proposal.

The distribution licensee i.e. UHBVNL, on behalf of both the Discoms, vide its Memo No. Ch-
02/RA/F-25/Vol-81 dated 22.03.2022, with reference to the letter to the MDs of the Discoms,
from the Govtt. Haryana / Power Department Memo No. Ch-238/DSO-512 has made the
following submissions:

That the Hon’ble Commission in the Tariff Order dated 30.03.2021 has approved the terms and
conditions of the TOU/TOD tariff as under:

i. Concessional Tariff or power drawn during off peak hours i.e. 21:00 to 05:30 hours, or
such time slots as the Discoms considers power to be surplus, in excess of normal
consumption during the corresponding month in the preceding year will be optional
and will be available only to HT Consumers, including furnaces, who opt for the
scheme, during the period November to March.

ii. The HT Consumer, desirous of availing this tariff as per the terms and conditions
proposed by the Discoms, shall submit the application to the Chief Engineer /
Commercial of respective Discom.

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iii. The Committee comprising of Chief Engineer/Commercial and SE / Metering &

Protection shall clear the applications, as far as possible, within the same day.
However, the decision shall in no case be delayed beyond three working days from the
date of receipt of the application.

iv. The Tariff, as given below, which shall be exclusive of FSA, ED and M. Tax, would be
applicable for the energy drawn during off peak hours i.e. 21:00 to 05:30 hours over
and above normal consumption in the corresponding month of the preceding year.
The energy drawn over and above the normal consumption, on which concessional
tariff would apply, would be equal to lesser of, where

x= Cumulative change in consumption during night hours (21:00 Hrs to 05:30 Hrs)
over the entire billing cycle

y= Cumulative change in total consumption during the 00:00 to 24:00 hours over the
entire billing cycle.

v. The base consumption for working out the change in consumption would be decided
by the Nigam on case-to-case basis keeping in view the factors like seasonality,
load/CD extension etc.

vi. The concessional tariff from November 2021 to March 2022 (for time slot of 21:00 to
05:30) shall be as under:

TOU/TOD Tariff

aa) HT Consumers on 11/33 kV : Rs 4.25/kVAh

bb) HT Consumers on 66 kV and above : Rs 3.75/kVAh

vii. Once opting to avail concessional tariff, the consumer would continue to be charged
concessional tariff for the entire duration of the Scheme from November to March.
The billing under concessional tariff shall commence from start of billing period
immediately following the date of acceptance of the application of the consumer.

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viii. Other terms & conditions of this tariff shall remain as per the ongoing approved
concessional tariff scheme.

ix. HT industry (including Arc furnace) HT NDS, Bulk Supply (other than Bulk Domestic).
The approved ToD/ToU Tariff shall be as under: -

Period Differential Tariff Time

For incremental consumption: -
HT Consumers on 11/33 kV- Rs 4.25/kVAh
Off-Peak Hours 09:00 P.M to 05:30 A.M
HT Consumers on 66 kV & above- Rs
3.75/kVAh
Normal Energy charges and applicable PLEC
Peak Hours 5:30 P.M to 09:00 P.M
charges
Normal Energy charges
Normal Hours 05:30 A.M to 5:30 P.M
determined by the Commission
Demand As determined by the Commission - shall be the same for all categories
Charges of consumers.

2. It has been submitted by the distribution licensee that the State Government, vide Memo
No. Ch. 238/DSO-512 dated 19.03.2022, has desired to encourage the electricity consumers
of industrial installation to use more electricity during night hours. Accordingly, the State
Discoms have been directed to make the amendment in existing terms and conditions of the
TOU/TOD tariff for implementation of the same to the industrial consumers in the State.

3. That the following amendments are desired to be considered by the state DISCOMs for
implementation of terms and conditions of TOU/TOD tariff for industrial consumers:

i. The continuous running industrial installation should be provided with

incentives against the additional energy drawn during night shift.

ii. The industrial installation which are running in shift should be provided with
the incentives against the shifting of energy drawn from day shift to night shift.

iii. The industrial installation which are running in single shift should be provided
with incentives against the additional energy drawn which they consume in the
night shift.

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Note: The above night-time concessional/incentive to be given to the industrial

installation should be over and above normal consumption in the corresponding
month of the preceding year.

4. That the amendment in the terms and conditions of TOU/TOD Tariff as specified above in
Point No. 5, may adequately be incorporated in a revenue neutral manner in the TOU/ TOD
tariff structure (mentioned above in Point No. 3) approved for the FY 2022-23.

5. The Commission has considered the above and is of the view that given the surplus power
during the off-peak hours and the need to dispose of the same in an optimum manner
instead of under-drawing and or selling in the day ahead market at an un-remunerative rate,
it would be appropriate to incentivise use of such power during the night time as well as off
peak hours of the day. This, the Commission feels would provide a big support to the
industrial consumers who are making efforts to get back on a high growth trajectory post
Covid-19 pandemic.

The Commission observes that the proposed amendment is already in vogue in Haryana.
However, for giving more impetus to the dispensations on ToD / ToU, the Discoms’ proposal
for continuous process industry, industrial installation running in shifts and able to shift their
load(s) to night shift as well as the industrial units operating in single shift and are able to
consume additional units during the night time, is allowed as prayed for by them, provided
the incremental / additionalities in energy drawl is quantified on the basis of the energy
recorded by the energy meter(s) .

The off-peak charges between 9 P.M to 5.30 A.M shall be Rs. 4.25 / kVAh (11/33 kV supply)
and RS. 3.75 / kVAh for supply at 66 kV and above. The demand charges shall be as per the
schedule of tariff and charges approved by the Commission in this order.
The concessional off – peak tariff / night time concession shall also be applicable for the EV
Charging stations for the entire energy drawl during the off-peak hours.

The ToD / ToU dispensation in vogue shall continue in the FY 2024-25 except for the timing
which shall be 9 P.M to 5.30 A.M or the time slots decided by the Discoms in view of power
surplus scenario after giving it a wide publicity provided there is a provision in the installed
meters for recording consumption in the particular time slot(s).
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CHAPTER 11
DISTRIBUTION & RETAIL SUPPLY TARIFF

The Discoms, in their petition, submitted that the Aggregate Revenue Requirement for FY 2024-
25 is estimated based on the audited accounts for FY 2022-23 and in accordance with the HERC
MYT Regulations. For True-up year FY 2022-23, Haryana Discoms are in a revenue deficit of
Rs.1,364.25 Cr., whereas revenue deficit for APR year FY 2023-24 is Rs 2,342.56 Cr & Rs 262.47
Crore after adjustment of Revenue Surplus of FY 2021-22 along with carrying cost. ARR year FY
2024-25 has a revenue deficit of Rs 1628.83 Cr, which is increased to Rs 3167.02 after adjustment
of revenue gap estimated for FY 2022-23 along with carrying cost.

UHBVNL, in its petition, further submitted that the DISCOMs expect to recover some portion of
this Gap based on the distribution loss efficiency gain and purchase of power at low cost in APR
and especially in ARR year. Discoms are currently in process of analyzing any requirement of tariff
modification. The same may please be allowed to be submitted as an additional submission at a
later stage if required.

DHBVNL, in its petition, has submitted that DISCOMs expect to recover some portion of this Gap
based on the efficiency gain in APR and ARR years. The remaining revenue deficit can be covered
through long-term/short-term loans.

The Commission observes that in view of the above, the Commission directs that in the next
ARR, the Discoms will submit a tariff proposal as well; it may not necessarily be for increase or
decrease in tariff(s) but for improvement in tariff design, reduction in the number of category
/ sub-category, re-alignment of demand / fixed charges etc. The proposal should include its
impact on a typical consumer.
Subsequent to the determination of the ARR for the FY 2024-25, the tariff now determined is
placed at Annexure – A.
The tariff (s) shall be applicable w.e.f. 01.04.2024 and shall continue to be vogue till the same
is amended / re-determined by the Commission.

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ANNEXURE – A
Schedule of Tariff and Charges
Tariff for 2023-24 (W.E.F. 01.04.2023) Tariff for 2024-25 (W.E.F. 01.04.2024)
Sr. Category of Energy Fixed Charge MMC (Rs. per Category of Energy Fixed Charge MMC (Rs. per
No. consumers Charges (Rs. per kW kW per consumers Charges (Rs. per kW per kW per month
(Paisa / per month of month of the (Paisa / month of the of the
kWh or/ the connected connected kWh or/ connected load connected
kVAh) load / per kVA load or part kVAh) / per kVA of load or part
of sanctioned thereof) sanctioned thereof)
contract contract
demand (in demand (in
case supply is case supply is
on HT) or as on HT) or as
indicated indicated
Domestic Supply Domestic Supply

Category I: Category I:
(Total consumption up to 100 units per month) (Total consumption up to 100 units per month)
0 - 50 units 200/kWh Nil Rs. 115 up to 2 0 - 50 units 200/kWh Nil Rs. 115 up to 2
per month kW and Rs. 70 per month kW and Rs. 70
51-100 250/kWh Nil above 2 kW 51-100 250/kWh Nil above 2 kW
Category II: Category II:
(Total consumption more than 100 units/month and up to 800 (Total consumption more than 100 units/month and up to 800
1
units/month)) units/month))
0-150 275/kWh Nil Rs. 125 up to 2 0-150 275/kWh Nil Rs. 125 up to 2
151-250 525/kWh Nil kW and Rs. 75 151-250 525/kWh Nil kW and Rs. 75
251-500 630/kWh Nil above 2kW 251-500 630/kWh Nil above 2 kW
501-800 and 710/kWh Nil 501-800 and 710/kWh Nil
above Above
Note: Benefit of Telescopic Tariff shall be restricted up to 800 Note: Benefit of Telescopic Tariff shall be restricted up to 800
Units/ Months for category II only i.e. 801 and above flat rate of Units/Months for category II only i.e. 801 and above flat rate of
710/kWh shall be applicable for the entire consumption. 710/ kWh shall be applicable for the entire consumption.
Non-Domestic (including Independent Hoarding/Decorative Non-Domestic (including Independent Hoarding/Decorative
2 Lightning/ Decorative Lightning / Temporary Metered supply and Lightning/ Decorative Lightning / Temporary Metered supply and
others) others)
Merged with LT Supply Tariff Merged with LT Supply Tariff
Merged with HT Supply Tariff Merged with HT Supply Tariff
Merged with HT Supply Tariff Merged with HT Supply Tariff
3 HT Supply (above 50 kW) inc. Traction and DMRC HT Supply (above 50 kW) inc. Traction and DMRC
Supply at 11 665/kVAh 165/kVA Supply at 11 665 / 165/kVA
KV including 738/kWh KV including kVAh 738
NDS existing in case of NDS existing / kWh in
consumers supply consumers case of
Nil Nil
above 50 kW continues above 50 kW supply
and upto 70 to be at LT and upto 70 continues
kW (LT) kW (LT) to be at
LT
Supply at 33 KV 655/kVAh 165/ kVA Nil Supply at 33 KV 655/kVAh 165/ kVA Nil
Supply at 66 kV 645/kVAh 165 / kVA Supply at 66 kV 645/kVAh 165 / kVA
Nil Nil
or higher or higher
Supply at 220 635/kVAh 165/ kVA Supply at 220 635/kVAh 165/ kVA
Nil Nil
kV kV
Supply at 400 625/kVAh 165/ kVA Supply at 400 625/kVAh 165/ kVA
Nil Nil
kV kV
Arc furnaces/ 695 Paisa 165 / kVA Arc furnaces/ 695 Paisa 165 / kVA
Steel Rolling per kVAh Steel Rolling per kVAh if
Mills also if supply is Nil Mills supply is at Nil
applicable to at 11 kV 11 kV
Open Access
4 LT Supply - up to 50 kW LT Supply - up to 50 kW
Upto 10 KW 635/kVAh Nil Rs. 185/kW Upto 10 KW 635/kVAh Nil Rs. 185/kW
or or
705/kWh 705/kWh
Above 10 KW 665/kVAh Nil Rs. 185/kW Above 10 KW 665/kVAh Nil Rs. 185/kW
& upto 20 kW or & upto 20 kW or
738/kWh 738/kWh

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Tariff for 2023-24 (W.E.F. 01.04.2023) Tariff for 2024-25 (W.E.F. 01.04.2024)
Sr. Category of Energy Fixed Charge MMC (Rs. per Category of Energy Fixed Charge MMC (Rs. per
No. consumers Charges (Rs. per kW kW per consumers Charges (Rs. per kW per kW per month
(Paisa / per month of month of the (Paisa / month of the of the
kWh or/ the connected connected kWh or/ connected load connected
kVAh) load / per kVA load or part kVAh) / per kVA of load or part
of sanctioned thereof) sanctioned thereof)
contract contract
demand (in demand (in
case supply is case supply is
on HT) or as on HT) or as
indicated indicated
Above 20 KW 640/kVAh Rs. 160/kW of Above 20 KW 640/kVAh Rs. 160/kW of
and upto 50 80% of the and upto 50 80% of the
Nil Nil
KW Connected KW Connected
Load Load
Existing Existing
consumers Merged with HT Supply consumers Merged with HT Supply
above 50 kW above 50 kW
upto 70 kW upto 70 kW
(LT) (LT)
h
5 Agro Indust / FPO 475 / kWh Nil Nil Agro Indust / FPO 475 / kWh Nil Nil
Agriculture Tube-well Supply Agriculture Tube-well Supply
Metered: 662 / Unit - Metered: 648 / Unit -
(i) with motor (i) with motor
upto 15 BHP Rs. upto 15 BHP Rs.
(ii) with motor 662/ Unit - 200/BHP/Year (ii) with motor 648 / Unit - 200/BHP/Year
above 15 BHP above 15 BHP
Un- Nil Rs. Nil Un- Nil Rs.
metered 15/BHP/Month metered 15/BHP/Month
(Rs. / Per (Rs. / Per
6 BHP/ BHP / Nil
Month): Month):
(i) with (i) with
motor motor upto
upto 15 15 BHP
BHP
(ii) with Nil Rs. Nil (ii) with Nil Rs. / Nil
motor 12/BHP/Month motor above 12/BHP/Month
above 15 15 BHP
BHP
Public Water 735 / Rs. 180 / kW or MMC of Rs. Public Water 735 / kWh Rs. 180 / kW or MMC of Rs.
Works / Lift kWh BHP except 165/kW/Month Works / Lift BHP except 165/kW/Month
7 Irrigation / Street Light only for Street Irrigation / Street Light only for Street
MITC / Street Light MITC / Street Light
Light Light
Railway Traction Railway Traction
Supply at 11 Merged with HT Supply Tariff at the respective Supply at 11 Merged with HT Supply Tariff at the respective
KV voltage of supply KV voltage of supply
Supply at 33 Supply at 33
8 KV KV
Supply at 66 Supply at 66
or 132 kV or 132 kV
Supply at 220 Supply at 220
kV kV
9 DMRC DMRC
Supply at 66 Supply at 66 Merged with HT Supply Tariff
kV or 132 kV Merged with HT Supply Tariff kV or 132 kV
Bulk Supply Bulk Supply
Supply at LT 650/kVAh 160/kW or Rs. Nil Supply at LT 650/kVAh 160/kW or Rs. Nil
Supply at 11 kV 640/kVAh 160/kVA as Nil Supply at 11 kV 640/kVAh 160/kVA as Nil
Supply at 33 kV 630/kVAh applicable (see Nil Supply at 33 kV 630/kVAh applicable (see Nil
10
Supply at 66 or 620/kVAh note 3) Nil Supply at 66 or 620/kVAh note 3) Nil
132 kV 132 kV
Supply at 220 615/kVAh Nil Supply at 220 615/kVAh Nil
kV kV
11 Bulk Supply Bulk Supply

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

Tariff for 2023-24 (W.E.F. 01.04.2023) Tariff for 2024-25 (W.E.F. 01.04.2024)
Sr. Category of Energy Fixed Charge MMC (Rs. per Category of Energy Fixed Charge MMC (Rs. per
No. consumers Charges (Rs. per kW kW per consumers Charges (Rs. per kW per kW per month
(Paisa / per month of month of the (Paisa / month of the of the
kWh or/ the connected connected kWh or/ connected load connected
kVAh) load / per kVA load or part kVAh) / per kVA of load or part
of sanctioned thereof) sanctioned thereof)
contract contract
demand (in demand (in
case supply is case supply is
on HT) or as on HT) or as
indicated indicated
(Domestic) (Domestic)
For total 525/kWh Rs.80 / kW / For total 525/kWh Rs.80 / kW / Nil
consumption month of the consumption month of the
in a month recorded in a month recorded
not demand not demand
Nil
exceeding exceeding
800 units/ 800 units/
flat/ dwelling flat/ dwelling
unit (DU). unit (DU).
For total 620/kWh Rs. 80 / kW / For total 620/kWh Rs. 80 / kW /
consumption month of the consumption month of the
in a month recorded in a month recorded demand
Nil Nil
exceeding demand exceeding
800 units/ 800 units/
flat/DU. flat/DU.
Notes:
1. In case of Arc furnaces/ Steel Rolling Mills for supply at 33 kV and above, the HT Industrial
tariff at the corresponding voltage level shall be applicable. The tariff determined in the
table above for Arc Furnace taking supply at 11 kV voltage, is inclusive of surcharge.
However, the open access consumers bringing in power under Open Access Mechanism
shall also pay a surcharge of 30 Paisa/unit.
2. Fixed charges for HT supply and Bulk Supply category are in Rs. / kVA of Contract Demand.
3. In case of Bulk Supply Consumers (other than Bulk Supply – DS), the fixed charges are in
Rs/kW of the connected load where contract demand is not sanctioned and in Rs. /kVA
of contract demand where contract demand is sanctioned.
4. Advocate’s Chamber, shall be levied a single rate (tariff) equivalent to CoS of LT Supply as
determined in the present order. There shall be no demand / fixed charges.
5. The electricity crematorium shall be levied a concessional tariff of Rs. 2.75 / Unit (kVA or
kWh). No demand charges shall be levied.
6. The schedule of tariff and charges does not include Electricity Duty, Municipal Tax,
Panchayat Tax (being levied as per the notifications issued by the State Government) and
FSA as per MYT Regulations in vogue.
7. Tariff for the eligible Gaushalas shall be Rs. 2.0 / kWh subject to payment of subsidy by
the State Government.
8. In case the State Government desires to extend concession including MMC/ subsidy to
any consumer category, the same shall be implementable subject to section 65 of the
Electricity Act, 2003.
9. The tariff for electricity supply to the EV Charging station in Haryana shall be a single part
tariff equivalent to the CoS of HT Supply and LT Supply, as determined in the present

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

order. The off peak / night-time concession benefits shall also be applicable. There shall
be no fixed / demand charges.
10. In the case of the existing consumers above 50 kW upto 70 kW (LT) that has been merged
with HT Supply, the tariff shall be as per HT Supply. In the absence of a compatible meter
standard power factor of 0.90 may be used. However, the Discoms shall ensure that a
compatible meter of requisite accuracy is installed either by the Discoms or by the
consumers themselves within six months from this order. It is clarified that consumer will
not have the option to pick and choose. However, such consumers shall be given option
either to get the load reduced below 50 KW or convert to HT metering within one year.
11. The tariff for places of worship shall be a single part tariff equivalent to the Domestic
Supply tariff(s).
12. The charges, other than energy and demand charges determined in the present order,
for NDS category merged with HT / LT Supply shall be as per the charges applicable for
erstwhile HT / LT Industry. The Discoms are directed to file a comprehensive proposal for
amendment in general and miscellaneous charges as well as the relevant regulations such
as the Duty to Supply Regulations.
13. The Temporary Supply Tariff shall remain unchanged i.e. as per the Commission’s tariff
order for the FY 2021-22.
14. The AP Supply tariff shall be Rs. 6.48 / kWh for metered supply and BHP (in the case of
flat rate shall be converted to kW and units worked out by applying the average running
hours of the tube-wells. However, the State Government may continue with the
subsidized tariff provided advance subsidy, in the beginning of each quarter is paid by the
State Government to the Discoms, as per Section 65 of the Electricity Act, 2003.
15. It is clarified that the acceptance limit of cash will be Rs. 5000 (five thousand). However,
the cash collection limit for theft penalty amount may be enhanced to Rs. 2,00,000 (two
lakhs); submission of PAN Card shall be mandatory for any transaction exceeding Rs.
50,000 (Fifty Thousand). It is further made clear that the AEE / SDO concerned shall be
fully responsible for cash collected and remittance into the designated bank(s) on the
same day.
16. The AP Tube-well tariff determined by the Commission u/s 62 of the Electricity Act, 2003
shall be levied by the Discoms in case the Government does not pay subsidy in accordance
with the provisions of Section 65 of the Electricity Act, 2003.
17. Green Energy premium shall be Rs. 0.88 / Unit over and above the normal tariff.
18. NDS consumers having sanctioned load above 50 KW and existing consumers having
sanctioned load above 50 KW and upto 70 KW (on LT Supply) have been merged with the
HT industrial consumers as “HT Supply”. In the absence of declared contract demand, as
well cumbersome process of asking all such consumer to declare their contract demand,
it would be appropriate, given the nature of NDS usage, that the sanctioned load of such
consumers available with the Discoms, is considered for levy of Fixed Charges.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

19. LT supply consumers (having sanctioned load up to 20 KW) shall be billed only on kVAh
tariff with the exception of billing in kWh only when the installed meter at consumer
premises is not kVAh compliant. However, Discoms shall ensure installation of kVAh
meters for such consumers by 30.09.2024.

All the directives contained in the various chapters of the present order as well as the Annexures,
shall be complied with by the Discoms within the timeline specified for the purpose.

This Order is signed, dated and issued by the Haryana Electricity Regulatory Commission on
5th March, 2024.

Date: 05.03.2024 (Mukesh Garg) (Naresh Sardana) (Nand Lal Sharma)

Place: Panchkula Member Member Chairman

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

ANNEXURE – B
Directives issued in the present order.
1. UHBVNL and DHBVNL are directed to intimate, within one month from the date of the
present order, the details of assets for which Capex were incurred and depreciation
claimed but remained stranded / un-utilised due to one reason or the other including
non-availability of associated lines / equipment etc.

2. The licensee(s) must ensure that consumers are paid interest on their Advance
Consumption Deposits duly reflected in their energy bills for the relevant month i.e. bill(s)
issued in the month of April / May.

3. In view of the discrepancies in the AP sales figures, the Commission directs that the MD
DHBVNL will check the figures of AP sales and input energy and submit a report on
running of AP tube wells on non-AP feeders within one month of issue of this order
besides reconciliation of figures as per order.

4. The Commission had rationalized certain tariff category and classified the same into HT
and LT Supply depending on the voltage of at which consumers in different categories
were taking supply. Hence, the same practice shall continue. The Discoms, may collate
data accordingly i.e. as per the merged categories instead of the categories that have
been dispensed with.

5. While resorting to bidding or calling for expression of interest for power procurement
the Discoms must ensure that the power under PPAs, already approved by the
Commission, materialises and also the intra-State generator, subject to MoD in vogue are
dispatched. However, it is reiterated that when contracting a new source of power supply
the landed cost of such power should be worked out in view of the General Network
Access charges in force.

6. In case additional power, if required, may be met from power allocated to Haryana from
the Central un-allocated quota with prior approval of the Commission. However, in case
of extreme emergency Discoms may schedule power subject to ex-post facto approval of
the Commission giving detailed justification, not later than 15 days thereof.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

7. The licensees are again directed to analyse and explain the aberrations in the MYT
projections and that proposed in the present petition i.e. map all the factors for the
increase including number of employees, contractual employees, DA, inflation factor etc.

8. The Discoms are directed to examine the discrepancies in its power purchase cost vis-à-
vis the cost projected to bring out the facts that would lead to reduction in cost of power
to the extent projected for the ensuing financial year. A report regarding the same may
be submitted within a month from the date of the present order.

9. The licensee needs to exercise proper monitoring of scheme wise execution of capital
works and control over the item wise expenditure approved by the Commission as per
Regulation 8.3.3 (b) of the Haryana Electricity Regulatory Commission (Terms and
Conditions for Determination of Tariff for Generation, Transmission, Wheeling and
Distribution & Retail Supply under Multi Year Tariff Framework) Regulations, 2019.

10. Both the licensees are further directed that they shall regulate their capital expenditure
plans for FY 2024-25 as per Regulations 9.7 to 9.12 of the Haryana Electricity Regulatory
Commission (Terms and Conditions for Determination of Tariff for Generation,
Transmission, Wheeling and Distribution & Retail Supply under Multi Year Tariff
Framework) Regulations, 2019.

11. The Commission again directs the DISCOMs to reduce AT&C losses of all urban feeders
below 25% and that of Rural feeders below 50% in FY 2023-24 and to submit the Status
Report after 2 months of the order.

12. The Commission again directs the licensees to bring down the distribution transformer
damage rate below the prescribed limits in FY 2023-24 and FY 2024-25. Any slippage on
account of the timeline shall lead to penalty as deemed fit and appropriate by the
Commission as per various provisions of the Act and Regulations framed thereunder.
Further Commission directs the licensee to provide the action plan and the action taken
to reduce rate DT damage during FY 2023-24 and FY 2024-25.

13. DHBVNL is again directed to clear the backlog of defective metering and to ensure that
at no point of time the percentage of defective meters exceeds 2% limit as per SOP
regulations in vogue.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

14. The Commission directs DISCOMs especially DHBVNL to replace all electromechanical
meters shown pending for replacement and submit compliance report within 3 months
from date of this order.

15. DISCOMs are directed to expedite the Installation of Smart Metering Project already
undertaken to ensure the competition of project within the timelines of agreement
executed between EESL and DISCOMs.

16. Further, DISCOMs to submit status of RFP/NIT along with their detailed plan regarding
replacing of conventional energy meters by prepaid smart meters within two months of
issuance of this Tariff Order.

17. The commission directs DISCOMs:-

i. To improve efficiency in the meter reading activities including billing.

ii. To reduce number of bills rendered on provisional basis.

iii. There should be no bill rendered on average basis for more than 2 billing cycles
failing which consumer shall be entitled to claim compensation.

18. It may be noted that in case batteries are installed by the Discoms at their sub-stations
and the same are charged during off-peak hours so that the stored power can be injected
back into the grid during peak hours to bridge any demand-supply gap, the same shall be
counted towards fulfilment of storage RPO.

19. Terminal Liability- The Discoms are directed to claim terminal liabilities based on actual
values instead of claiming the same on the basis of actuarial valuation. Any aberrations
can be trued up.

20. R&M- The Commission has observed that the discoms are always short of spending the
full amount on Repair & Maintenance as approved by the Commission. It needs to be
noted that R&M expenses are crucial to keep the distribution system in a perfect
condition and to prevent unscheduled outages. Hence, they are directed to utilise the
R&M expenses prudently to ensure quality and continuity in supply of power.

21. Arrears/Collection Efficiency- The discoms are directed to segregate the collection of
revenue pertaining to a financial year into current revenue collection and revenue

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collection pertaining to arrears, to make the collection efficiency report more

meaningful/accurate. Hence, the same is not reported as more than 100%.

22. Power Planning- The Commission has observed that, with the concurrence of the
Discoms, more than one unit of HPGCL’s power station / other power stations are taken
out for planned maintenance at the same time. The Discoms are directed to assess their
power demand /supply position as well as the prevailing market conditions in the power
exchanges / bilateral sources and then only take an informed decision of allowing power
generating station(s) to be simultaneously taken out for planned maintenance.

23. Any other directive issued in the present order shall be complied with by the Discoms
in a time bound manner.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

ANNEXURE – C
Directive Compliance Status of order dated 15.02.2023- UHBVNL
# Directives Letter no. UHBVNL Reply Remarks
and date
1 UHBVNL Vide It is submitted to the Hon'ble Commission that the assets for which Complied
and memo no capex is incurred are being utilized at their fullest capacity, with
DHBVNL Ch-20 F- therefore no assets are stranded / un-utilized. The depreciation is As stated in
are directed 173 Vol- claimed as per the HERC MYT Regulations 2019 and its the reply by
to intimate, 14 dt amendments thereof. UHBVN,
within one 13.03.202 there is no
month from 3 asset for
the date of which
the present Capex were
order, the incur and
details of depreciatio
assets for n claimed
which but
Capex were remained
incurred stranded /
and un-utilized.
depreciatio
n claimed
but
remained
stranded /
un-utilized
due to one
reason or
the other
including
non-
availability
of
associated
lines/
equipment
etc.
2 The Vide It is submitted that the compliance of directive of HERC has been Complied
licensee(s) memo no made and the interest on ACD is initiated / reflected in consumer with
must Ch- bills w.e.f. 1st April/2023
ensure that 48/RA/F-
consumers 173/Vol–
are paid (14) dated
interest on 03.05.202
their 3
Advance
Consumpti
on Deposits
duly
reflected in
their energy
bills for the
relevant
month i.e.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
bill(s)
issued in
the month
of April /
May
3 In view of Does not relate to UHBVNL Does not
the relate to
discrepanci UHBVNL
es in the AP
sales
figures, the
Commissio
n directs
that the MD
DHBVN will
check the
figures of
AP sales
and input
energy and
submit a
report on
running of
AP tube
wells on
non-AP
feeders
within one
month of
issue of this
order
besides
reconciliati
on of
figures as
per order.
4 The Vide UHBVN is already classified LT & HT category as per merged Complied
Commissio memo no categories of tariff and compiling the data accordingly from F.Y. with
n had Ch- 2022-23 onwards.
rationalized 11/RA/F-
certain 173 Vol-
tariff 14 dt.
category 07.03.202
and 3
classified
the same
into HT and
LT supply
depending
on the
voltage of
at which
consumers

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# Directives Letter no. UHBVNL Reply Remarks

and date
in different
categories
were taking
supply.
Hence, the
same
practice
shall
continue.
The
Discoms,
may collate
data
accordingly
i.e. as per
the merged
categories
instead of
the
categories
that have
been
dispensed
with
5 While Vide The direction of Hon’ble Commission has been noted. It is Complied
resorting to memo no submitted that as per HERC order, Practice is being followed by with
bidding or Ch- HPPC to contract the new source of power supply under long term,
calling for 36/RA/F-
medium term & short-term basis after comparing the landed cost
expression 173/Vol-
of interest (14) dated of such power with the cost of power from state generating station
for power 28.04.2023 i.e. HPGCL.
procureme
nt the
Discoms
must
ensure that
the power
under PPAs,
already
approved
by the
Commissio
n,
materialise
s and also
the intra-
State
generator,
subject to
MoD in
vogue are
dispatched.
However, it

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# Directives Letter no. UHBVNL Reply Remarks

and date
is reiterated
that when
contracting
a new
source of
power
supply the
landed cost
of such
power vis-
à-vis cost of
power from
HPGCL’s
power
stations
shall be
reckoned
with
instead of
MoD
prepared
on the basis
of variable/
fuel cost.
6 In case Vide The direction of Hon’ble Commission has been noted. HPPC has Complied
additional memo no filed a petition dated 06.04.2023 before HERC to seek approval to with
power, if Ch- purchase power from unallocated quota of central generating
required, 36/RA/F- stations in line with MoP order dated 22.03.2023.
may be met 173/Vol-
from power (14) dated
allocated to 28.04.2023
Haryana
from the
Central un-
allocated
quota with
prior
approval of
the
Commissio
n. However,
in case of
extreme
emergency
Discoms
may
schedule
power
subject to
ex-post
facto
approval of
the

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# Directives Letter no. UHBVNL Reply Remarks

and date
Commissio
n giving
detailed
justification
, not later
than 15
days
thereof.
7 The Vide It is submitted that the projections for ARR year i.e., FY 2023-24 Complied
licensees memo no are done as per the Haryana Electricity Regulatory Commission with.
are again Ch- (Terms and Conditions for Determination of Tariff for Generation,
directed to 27/RA/F- Transmission, Wheeling and Distribution & Retail Supply under
analyse and 173/vol Multi Year Tariff Framework) Regulations, 2019 and its
explain the (14) dated amendment thereof.
aberrations 12.04.202 The employee expense for ARR year is calculated by considering
in the MYT 3 the revised estimated employee expenses for APR year and
projections inflation factor i.e., 6.10%, along with the dearness allowance of
and that 8% is considered, which is additionally disbursed by the
proposed in government of Haryana in the APR year, the same is indexed for
the present calculation of corresponding expenses for ARR year.
petition i.e. The MYT projections done taking actual employee expenses of FY
map all the 2018-19 and escalating it @ 4% to arrive at the base year value for
factors for the MYT Control Period. The base year employee expenses are
the indexed with inflation factor of 4.66% to project the employee
increase expenses of UHBVNL for ensuing years of the MYT Control Period.
including UHBVN in present petition has projected employees cost for FY
number of 2023-24 considering following factor:
employees, i. Indexation Factor:
contractual Employee Expense of ARR year (FY 2023-24) is computed by
employees, escalating previous year employee expense by indexation factor.
DA, Following is the calculation of indexation factor considered for
inflation escalation of employee cost:
factor etc CPI Indices^ WPI Indices#
Month FY 2021-22 FY 2022-23* FY 2021-22 FY 2022-
23*
April 345.9 367.8 132.0 152.3
May 347.3 371.5 132.9 155.0
June 350.5 372.1 133.7 155.4
July 353.7 374.1 135.0 154.0
August 354.2 375.0 135.9 153.1
September 355.1 378.1 136.0 152.1
October 359.7 - 137.4 -
November 362.0 - 140.7 -
December 361.2 - 143.7 -
January 360.3 - 143.3 -
February 360.0 - 143.8 -
March 362.9 - 145.3 -
Average 356.1 373.1 139.4 153.7

*Since, at time of Tariff Filing CPI & WPI for FY 22-23 is available up
to September, 2022 accordingly same is considered for
computation of indexation factor.
^In September' 20, the base year of CPI has changed from 2001 to
2016 for which linking factor of 2.88 as specified by the Labour
Bureau of India is considered for determination of indexation
factor.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
Source of CPI: http://www.labourbureaunew.gov.in/
#Source of WPI:
https://eaindustry.nic.in/wpi_press_release_archive.asp
Considering above indices, Indexation Factor has been computed
as per Regulation 57.4 of HERC MYT Regulations, 2019, is as below
Particulars WPI CPI Total
Weightage 0.45 0.55 1
Avg Indexation for FY 153.7 373.1
2022-23
Avg Indexation n 69.1 205.2 274.3
(Index * Wt.)
Avg Indexation for FY 139.4 356.1
2021-22
Avg Indexation n-1 62.7 195.8 258.6
(Index * Wt.)
Combined Inflation 6.10%
(Indxn/Indxn-1)
ii. Recruitment Plan:
UHBVN has also considered the fact that Discom has planned to
scale up its existing infrastructure & strengthen IT backbone for
robust distribution network. To upkeep the discom with rapid
changing technology in distribution sector specialized manpower
needs to be recruited from time to time.
Further, considering the basic salary of Rs. 25,000/- and applicable
dearness allowance, employee cost for new recruitments is
included over and above the employee cost estimation explained
in previous point.
iii. Dearness Allowance:
Rate of Dearness Allowance applicable to Haryana Government
employees as notified by the Govt. of Haryana is show in table
below:
Haryana Government Notification
With effect from DA (%)
No. & Date
4/1/2017-2 FR/32148 dated
01/07/2019 17%
25.11.2019
4/12019-1FR/26553 dated
01/07/2021 31%
23.12.2021
01/01/2022 4/1/2019-1FR/0 dated 28.04.2022 34%
4/3/2016-5FR/22747(2) dated
01/07/2022 38%
10.10.2022
The annual DA growth of 8% is considered in FY 2023-24.
As seen from above, the variation in employee expense as
estimated at the time of MYT projections and ARR projection is
basically due to inflation factor and DA payout by Government of
Haryana.
8 In case of Does not relate to UHBVNL Does not
DHBVNL, it relate to
is observed UHBVNL
that the
actual rate
of interest
of working
capital for
FY 2021-22
comes out
to be ~21%,
as per the

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
additional
data
submitted
by the
Nigam vide
email.
There is
some
discrepancy
in the data
sheet as to
inappropria
te
disclosure
of opening
and closing
balances of
the working
capital loan
accounts in
the data
sheet,
leading to
computatio
n of
incorrect
actual rate
of interest
on working
capital. In
view of
above, the
Commissio
n directs
the Nigam
to look into
the reasons
for
submitting
incorrect
data and
report the
accurate
the rate of
interest
paid by the
licensee for
the FY
2021-22 on
working
capital
loans. Also,
both the

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
Discoms to
ensure that
accurate
and
complete
information
is
submitted
along with
the ARR
petitions
every year.
9 The Vide It is submitted that the Discoms have projected the power Complied
Commissio memo no. purchase cost for FY 2023-24 excluding the unprecedented with
n has noted Ch- circumstance of increase in variable cost due to blending of
with the 55/RA/F- imported coal as per MoP directives and due to unavailability of
concern 173 Vol- power from APL, CGPL, Faridabad Gas & Khedar (during Q1) in FY
that the 14 2022-23. Due to unavailability of these sources and to provide
average dt. continuous power in Haryana, power was purchased from
cost of 09.05.202 alternate sources including short term and Exchange. The prices in
power 3 power exchange were on higher side during FY 2022-23.
(without In the petition, the projections for availability of power have been
transmissio undertaken only from long-term sources. Furthermore, it is
n cost) for submitted that impact of any variation in variable charges due to
the FY blending or external factors affecting GCV or fuel price could not
2023-24 be ascertained with accuracy at the time of filing of petition and as
has been such variable charges are captured through FSA only. Hence,
projected Discoms found it appropriate to project the power purchase cost
by the on normalized assumptions considering business as usual scenario
Discoms at with an understanding that the impact if any is to be taken on
Rs. 3.83 / actual as per the MYT Regulations.
Unit, while Further, it is humbly submitted that variable charges during FY
the same in 2022-23 has the impact of imported coal blending, which is
the FY significantly higher than the actual variable charges of FY 2021-22.
2022-23 (up Hence, variable cost of FY 2022-23 cannot be used as the base for
to the purpose of estimating the variable cost (Rs. Cr.) of FY 2023-24.
December Thus, the variable charges (Rs/kWh) for the respective generating
2022 has stations are considered same as variable charges (Rs/kWh) of FY
been more 2021-22 with 0% escalation. Further, for the generating stations,
than whose variable charges were not available on actual basis during
Rs.5/Unit. FY 2021-22, variable charges of FY 2022-23 for the respective
Moreover, generating stations are considered, for the purpose of estimation
the landed of variable cost. The Fixed Cost estimation is carried out on pro-
cost of rata basis by considering the Fixed Cost of FY 2022-23 for the
short-term respective generating station with 0% escalation.
power In addition, to the above, it is submitted that, no blending impact
proposed has been considered in case of Thermal Generating Stations while
for the estimating the Power Purchase Cost of FY 2023-24 since the
considerati blending of imported coal is decided by the MoP from time to time
on and keeping in view the availability of domestic coal. The power
approval of procurement has been considered keeping in view availability of
the power at normative PLF from long term sources. Further, the
Commissio petitioner in this present ARR petition, has not considered any

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
n is also prior period expenses impact that may be allowed by various
significantly courts of law in order to avoid over-estimation in the overall Power
higher and Purchase Cost.
spills over
to the
months, so
far,
considered
as off –
peak
months.
The
Discoms are
directed to
examine
the
discrepanci
es in its
power
purchase
cost vis-à-
vis the cost
projected
to bring out
the facts
that would
lead to
reduction in
cost of
power to
the extent
projected
for the
ensuing
financial
year. A
report
regarding
the same
may be
submitted
within a
month from
the date of
the present
order.
1 The Vide It is submitted that the capital expenditure works are being Complied
0 licensee memo no monitored by Nigam Officials at the highest level. The scheme-wise with
needs to Ch-20 F- execution of capital works and control over the item-wise As per tariff
exercise 173 Vol- expenditure as approved by the Commission are supervised and order dated
proper 14 dt reviewed by the Nigam Officers on a regular basis. The capex is 15.02.2023,
monitoring 13.03.202 controllable element of ARR as per Regulation 8.3.8 (b) of HERC for the
of scheme 3 MYT Regulations, 2019. Further and barring unforeseen true-up

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
wise circumstances, Nigam takes concerted efforts to ensure that actual year 2021-
execution capital expenditure is as close to the approved capital expenditure 22, UHBVN
of capital as possible. was able to
works and incurred
control Capex of
over the Rs. 947.37
item wise Cr. against
expenditur approved
e approved capex of
by the Rs. 950 Cr.
Commissio Therefore,
n as per the actual
Regulation capital
8.3.3 (b) of expenditur
the e for 2021-
Haryana 22 was very
Electricity close to the
Regulatory approved
Commissio expenditur
n (Terms e.
and
Conditions
for
Determinati
on of Tariff
for
Generation,
Transmissio
n,
Wheeling,
and
Distribution
& Retail
Supply
under Multi
Year Tariff
Framework
)
Regulations
, 2019.
1 Both the Vide The Capex plans as approved in the Tariff Order for FY 2023-24 is Complied
1 licensees memo no generally and will be regulated by Nigam as per the direction of the with
are further Ch- Hon'ble Commission. Further, the Nigam, being a regulated entity, Licensee
directed 20/RA/F- follows the HERC MYT Regulations, 2019 and its amendments assured to
that they 173 Vol- thereof. The capital investment plan envisaged by Nigam is also regulate
shall 14 dt shared with Genco and Transco in due time in order to create sync the Capex
regulate 13.03.202 between the investments proposed by all utilities. It will also be as per
their capital 3 ensured that any additional capital expenditure incurred due to direction.
expenditur time over-run or unapproved schemes, or changes shall not be
e plans for considered in capital expenditure to be claimed during true-up
FY 2023-24 without any reasonable justification and the same shall be subject
as per to approval from the Hon’ble Commission.
Regulations

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
9.7 to 9.12
of the
Haryana
Electricity
Regulatory
Commissio
n (Terms
and
Conditions
for
Determinati
on of Tariff
for
Generation,
Transmissio
n,
Wheeling,
and
Distribution
& Retail
Supply
under Multi
Year Tariff
Framework
)
Regulations
, 2019.
1 The Vide No. of feeder more than 50% in RDS category and urban feeders Partially
2 Commissio memo no more than 25% complied
n again Ch- Sr. Circle RDS Urban with
directs the 33/RA/F- no April to April to April to April to Although
DISCOMs to 173/Vol- March,2022 march, March,2022 march, there is
reduce 14 dated 2023 2023 improveme
AT&C losses 24.04.202 Above 50% Above 25% nt but the
1 Panchkula 0 0 0 0
of all urban 3 feeders
2 Ambala 0 1 3 0
feeders with higher
3 Yamunanagar 0 0 0 0
below 25% 4 Kurukshetra 0 0 0 0
losses are
and that of 5 Kaithal 11 6 4 2 still there.
Rural 6 Karnal 0 0 0 0 More effort
feeders 7 Panipat 16 4 4 0 required to
below 50% 8 Sonepat 62 24 10 2 make the
in FY 2022- 9 Rohtak 42 39 2 0 count Nil.
23 and to 10 Jhajjar 47 18 1 0
submit the UHBVNL 178 92 24 4
Status
Report
after 2
months of
the order.
1 The Vide As per HERC SOP Regulations, 2020 (6.1.e), Discoms have to Partially
3 Commissio memo no maintain DT damage rate below 6% p.a. in rural areas and 3% p.a. Complied
n again Ch-11 F- in urban areas. The Financial Year wise data of DT damage rate more effort
directs the 173 Vol- is as follows: - required to

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
licensee to 14 dt. FY DTs damage Rate% Increase/Decrease in
be put in to
bring down 07.03.202 Rural Urban Rural reduceUrban
the
the 3 2016-17 11.20 6.31 +1.90 -0.87
transforme
distribution 2017-18 9.84 7.06 -1.36 +0.75
r damage
2018-19 10 19 5.64 +0.35
transforme rate. -1.42
2019-20 9.60 5.62 -0.59 -0.02
r damage
2020-21 9.15 5.09 -0.45 -0.53
rate below 2021-22 8.69 5.63 -0.46 +0.54
the 2022-23 (up to Jan,23) 7:16 4.27 -1.53 -1.36
prescribed The following action plan has been circulated in field offices to
limits in FY maintain DT damage rate below 6% in rural & 3% urban areas,
2022-23 during F.Y. 2022-23 & F.Y. 2023-24: -
and FY i. Sufficient numbers of LT circuit with separate fuse system
2023-24. will be provided on higher capacity DTs
Any 100 KVA – Up to 2 Circuits
slippage on
200 KVA -Minimum 2 Circuits
account of
the timeline 400 KVA – Minimum 3 Circuits
shall lead to 630 KVA – Minimum 4 Circuits
penalty as ii. Load on each phase of the Transformer and carrying out
deemed fit the load balancing exercise.
and iii. Oil level of transformer be checked and be topped up
appropriate wherever required.
by the iv. Condition of silica gel breather be checked, wherever
Commissio applicable and necessary action be taken.
n as per v. LT fuse boards be checked and replaced wherever
various required.
provisions vi. LT rods be checked and replaced wherever required.
of the Act vii. Proper termination with appropriate sizes of Aluminum
and Thimbles be done.
Regulations viii. Additional Transformer will be provided to give relief to
framed overload transformer.
thereunder. ix. Augmentation of transformer will be carried out.
Further, x. Conditions of LT cables be checked and worn-out cables be
Commissio replaced wherever necessary with appropriate size of
n directs cable.
the licensee xi. Condition of male & female contacts of GO switches and
to provide remedial action be taken accordingly.
the action Further, in every WTDs & BODs meeting, monthly damage
plan and rate of Distribution Transformers is reviewed, and directions
the action are imparted to field offices for reducing the damage rate,
taken to Vide otherwise disciplinary action would be initiated against the
reduce rate memo no delinquent officers/officials.
DT damage Ch-
during FY 70/RA/ F- The updated data regarding the same will be submitted along with
2022-23 173 Vol- filing of ARR Petition for FY 2024-25.
and FY 14
2023-24. dt.16.05.2
023
1 DHBVN is Does not relate to UHBVNL Does not
4 again relate to
directed to UHBVNL
clear the
backlog of

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
defective
metering
and to
ensure that
at no point
of time the
percentage
of defective
meters
exceeds 2%
limit as per
SOP
regulations
in vogue
1 The Vide The status of single phase and three phase mechanical/electro- Partially
5 Commissio memo no mechanical meters as on 28.02.2023, is as under: - Complied
n directs Ch-11 F- Sr. Name Number of Progress of replacement Number of with.
DISCOMs 173 Vol- No. of Mechanical/ of Mechanical/ Mechanical As on
Circle Electromechanical Electromechanical /Electromechanical
especially 14 dt. meters pending for meters during 1.04.2022 meters pending for 28.02.2023
DHBVN to 07.03.202 replacement at the end to 28.02.2023 replacement as on , there is no
replace all 3 of March 2022 28.02.2023 pending
electromec Single Three Three Single Three three phase
Single Phase
hanical Phase phase phase Phase Phase electro-
meters mechanical
1 AMB 10488 719 10488 719 0 0
shown meters left
2 PKL 1524 472 1524 472 0 0
pending for for
replacemen 3 YNR 4522 0 4522 0 0 0 replaceme
t and 4 KKR 0 0 0 0 0 0 nt.
submit 5 KTL 409 0 409 0 0 0
However,
compliance 17,191
6 KNL 21 30 21 30 0 0
report single
within 3 7 PNP 1053 0 1053 0 0 0 phase
months 8 SNP 28784 700 14766 700 14018 0 electromec
from date 9 RTK 13383 0 12035 0 1348 0
hanical
of this meters in
10 JJR 5737 0 3912 0 1825 0
order. Sonipat
Total 65921 1921 48730 1921 17191 0
UHBVN
(14018),
Rohtak
It is submitted that there is no pendency left for replacement of
(1348) and
three phase electro-mechanical meters in all OP Circles. The
Jhajjar
balance single phase meters are installed in rural areas of Sonipat,
(1825)
Rohtak & Jhajjar Circle which are being replaced in villages where
reported to
MGJG work is under progress and not started yet. However, stiff
be replaced
resistance is being faced in these 'OP' Circles. The progress of
on priority.
replacement of electro-mechanical meters is regularly reviewed
Sincere
under the Chairmanship of Worthy Managing Director/Director
efforts
Operation, UHBVN. The directions have been imparted to replace
required to
the remaining 17191 No. single phase electro-mechanical meters
zero down
on priority.
the
pendency.

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
1 DISCOMs Vide The work of smart meter installation has been suspended by EESL Partially
6 are directed memo no from 01.02.2023. Notice of Default has been issued to M/s EESL on complied
to expedite Ch- 01.03.2023 in tune of MoU and contract agreement. Further, EESL with
the 25/RA/F- has been directed to resume the work and services within 15 days.
Installation 173/ Vol- 3,91,544 no. of smart meters have been installed (against 5 Lakh) in
of Smart 14 UHBVN as on date. As per contract agreement, EESL has to
Metering dated11.0 complete the project by Dec 2023.
Project 4.2023
already
undertaken
to ensure Vide The updated progress report will be shared alongwith the filing of
the memo no ARR Petition for FY 2024-25.
competitio Ch-
n of project 70/RA/ F-
within the 173 Vol-
time lines 14 dt.
of 16.05.202
agreement 3
executed
between
EESL and
DISCOMs
1 Further, Vide Keeping in view the challenges faced in EESL project on DBFOOT Not
7 DISCOMs to memo no model, Haryana Discoms are pursuing the matter with MoP to allow Complied
submit Ch- the prepaid smart metering implementation under RDSS on Latest
status of 25/RA/F- CAPEX/Hybrid financing model to retain the ownership of AMI status
RFP/NIT 173/ Vol- application as long-term vendor lock-in will create a monopolistic submitted
along with 14 dt situation favoring AMI-SPs who may compromise with meter but action
their 11.04.202 quality and ignore Discom/Consumer's genuine concerns. The still
detailed 3 decision for floating of tenders will be finalized once mode of pending.
plan implementation is decided by the state government.
regarding
replacing of
convention
al energy Vide Further, it is submitted that the status of the RFP/NIT for
meters by memo no engagement of AMI-SP for implementation of prepaid Smart
prepaid Ch- Metering under UHBVN remains the same i.e. the mode of
smart 70/RA/ F- implementation of Smart Meter Project is under consideration
meters 173 Vol- /decision by State Government.
within two 14 dt.
months of 16.05.202
issuance of 3
this Tariff
Order.
1 The Vide i. Improvement in downloading of meters. Partially
8 commission memo no complied
a. There are approx. 31 lac consumers in UHBVN (Except AP) and
directs Ch-20 F-
out of these meters approx. 80% meters are downloadable
DISCOMs:- 173 Vol- -Showing
and currently the downloading percentage is approx. 75% of
i. To 14 dt reduction
total consumers or more than 90% of the downloadable
improv 13.03.202 in
consumers. The status of meter reading downloaded is given
e 3 provisional
below (Nov & Dec-22): -
efficien billing from
Discom Jan-21 Feb-21
cy in 5.42 % in

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
the Total Downloading % Total Downloading Dec, 2021
meter Consumer (w.r.t total Consumer % (w.r.t total to 2.97% in
reading UHBVN meters meters Jan, 2023.
activiti 1392781 36.78 1549652 40.62 -Licensee
es further
includi Disc Nov-22 Dec-22 submitted
ng om that
billing. Total Downlo Downloa Total Downlo Downloa continuous
ii. To Consu ading % ding % Consu ading % ding % efforts are
reduce UHB mer (w.r.t (w.r.t mer (w.r.t (w.r.t being made
numbe VN total downloa total downloa to achieve
meters dable meters dable
r of bills the
meters meters
render permissible
14792 74.62 90.88 12869 75.09 90.11
ed on 03 24 limit of
provisi b. High billed logic has been modified; hence it will improve the provisional
onal meter reading and billing performance. billing,
basis. c. MNF (Meter Not Found), ANT (Address Not Traceable) is which is
iii. There closely monitored by concerned SDOs/OP and the progress is 0.1% as per
should monitored on monthly basis by Director/OP. SoP
be no ii. To reduce number of bills rendered on provisional basis. regulations.
bill
render a. Current status of provisional billing as well as defective
ed on meters for the month of Dec-22 & Jan-23 is placed at
averag Annexure-A & B respectively.
e basis The progress of provisional billing is as under: -
for Status of provisional billing
more Sr. No Period % Provisional billing
than 2 1 Dec-21 5.42
billing 2 Jan-22 5.04
cycles 3 Feb-22 5.61
failing 4 Mar-22 5.02
which 5 Apr-22 4.67
consum 6 May-22 5.19
er shall 7 Jun-22 5.78
be 8 Jul-22 5.14
entitled 9 Aug-22 4.27
to claim 10 Sep-22 3.56
compe 11 Oct-22 3.36
12 Nov-22 3.27
nsation
13 Dec-22 2.91
.
14 Jan-23 2.93

The above table shows there is continuously improvement

in provisional billing cases and NIGAM is trying that no bill
will be issued on average basis for more than two billing
cycle.
b. One number JSEs has been deputed at division level to
monitor the billing and consumer complaints on daily basis
hence UHBVN reduced the provisional billing to 2.93% Jan-
23).
iii. There should be no bill rendered on average basis from
more than 2 billing cycles failing which consumer shall be
Vide
entitled to claim compensation.
memo no

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
Ch- a. Nigam is continuously monitoring the defective meter
70/RA/ F- cases. This results in timely replacement of defective
173 Vol- meters hence this exercise will reduce the repeated
14 dt. average billing.
16.05.202 b. The status of pending complaints (BR/MCO/PDCO) is
3 reviewed on monthly basis by Director/OP, this leads to
timely resolution of complaints.
The percentage of provisional billing ending March’23 is 3.32%
which was at 5.02% in March’22 and 5.42% in December’21.
Further, it is submitted that efforts are being made by Nigam to
reduce the provisional billing.
1 It may be Vide It is submitted that DHBVN has already finalized the RFP and got Complied
9 noted that memo no approved from BODs. with
in case Ch- Accordingly, UHBVN has requested DHBVN to include 2 no. 5MW
batteries 59/RA/F- Battery Energy Storage System (Panipat Jhajjar Circle) in their RFP.
are 173/Vol– The Tendering for the said works is under process by DHBVN
installed by (14) dated
the Discoms 09.05.202
at their sub- 3
stations
and the
same are
charged
during off-
peak hours
so that the
stored
power can
be injected
back into
the grid
during peak
hours to
bridge any
demand-
supply gap,
the same
shall be
counted
towards
fulfilment
of storage
RPO.
2 Page 185 Vide It is submitted that subsidized tariff for AP category has been Complied
0 The memo no retained at par with previous year's AP tariff. with
petitioners Ch- The State Government has released subsidy of Rs. 230 Crore in FY
are directed 48/RA/F- 2022-23 on account of FSA pertaining to AP consumers. The State
to ensure 173/Vol– Government has provided a budget of Rs. 600 Crore on account of
that supply (14) dated FSA pertaining to AP consumers in the FY 2023-24.
of power to 03.05.202 Further, the sanction orders of Rs. 1592.50 core & Rs. U./5 Crore
AP / any 3 for release of RE subsidy and Gaushala subsidy respectively for the
categories 1st quarter of FY 2023-24 has been issued by the office of
of

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
consumers, Additional Chief Secretary to Govt. Haryana, Energy
where the Department
State
Governmen
t has
committed
a subsidized
tariff, is
strictly in
accordance
with section
65 of the
electricity
act, 2003.
2 Page no 186 Vide Vide memo no. Ch-23/RA/F-173/ Vol-14 dated 20.03.2023 Complied
1 The memo no. The Hon’ble Commission Vide Tariff Order dated 15.02.2023 (page with
Discoms are Ch- no 186) has directed the Discoms to file revenue realized from
directed to 23/RA/F- MMC for FY 2022-23.
file revenue 173/ Vol- In this regard, the reply in respect of above said directive is as
realised 14 under: -
from MMC dated (Amount in Rs.)
in the FY 20.03.202 MONTH MMC MMC AMT AMT TO CURR CYC REALIZATION
2022-23 3 BILL COVER MMC CHARGES
COUNT
within one April 2022 281910 191381988 91374474 200665756 121612494
month from May 2022 189582 140329806 70416916 146914335 139200556
the date of June 2022 188579 144017390 75967690 151598454 149086191
this order July 2022 169528 129667086 69171547 149157203 158452208
August 2022 188549 141436848 78483898 164770062 171860712
Sep2022 242020 221609978 103817822 255741372 187686874
Oct 2022 256614 185016326 95629150 213065223 230817040
Nov 2022 385182 243286858 122442939 297403107 401596391
Dec 2022 621255 336592057 159526304 458803220 532878535
Jan 2023 758827 451465736 206168263 566970561 597334405
Feb2023 788095 418425714 210764197 518667711 607266590
March 2023 341410 187522049 90383109 235940363 274260864
Total 4411551 2790751835 1374146310 3359697368 3572052860
*since payment is collected against A/c no., therefore it won’t
possible to provide actual realization against Bill ID raised on MMC
basis. For preparing realization data amount of latest payment
made by consumer after generation of MMC Bill is considered.
2 Page no 195 Vide The Capex Plan submitted for APR year at the time of filing ARR Complied
2 UHBVNL is memo no. petition was upto Sep. 2022. The works at Sr. No. 7, 9, 10, 11, 12, with
directed to Ch- 14 (2) & 16 were under tendering/ approval process. Further these
give the 61/RA/F- works were carried out in the 2nd half of the FY 2022-23. The detail
justification 173 Vol- is as under: -
of nil 14 Sr. Description Reply
expenditur dt. No
e against 10.05.2023 7 Civil allied Works other Rs. 5.31 Cr. has been incurred
the than substation during FY 2022-23
buildings
approved
9 Strengthening of 11 kV Rs. 50.50 Cr. has been incurred
capex and
lines, 11 kV Ring Main during FY 2022-23
to adhere System, New DTs &
to the normal development
Regulation 10 Creation of double The works at Sr. No. 10 of the
meticulousl supply source for 33 kV capex Plan i.e. "The creation of

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
y. substations, 33 kV Ring double supply source for 33 kV
Main / Scada Sub-stations, 33 kV Ring MaW
SCADA." The creation of double
supply source for 33 kV Sub-
stations, 33 kV Ring Main/ Scada
was envisaged at the beginning of
the financial year. This
arrangement was to be done to
make sure the availability of
uninterrupted power 24x7, due to
maintenance work or outages.
For this arrangement UHBVN
approached HVPN to get access of
bays at feeding sub-stations of
HVPNL. All SE' s (OP) UHBVN have
also been asked to identify &
supply the data of 33 kV Sub-
stations for the creation of double
supply source.
The above proposal is under
process & likely to be finalized in
this financial year.
The reason as explained above
lead to nil expenditure for the said
capex works
11 Revamped Distribution Work yet to be awarded and NITs
Strengthening Scheme are under evaluation stage.
(RDSS)
12 Electric Vehicle Work order of amounting to Rs.
Charging 27 Lakhs was allotted for EV
Station charger at Head Office Building of
UHBVN, Panchkula and work was
completed.
14(2) Commercial Data 1.Invoice not raised by firm.
Migration (IPDS & 2. Migration of Non-R consumers
Balance Areas) on CC &B of all 10 circles has been
100% completed
16 ERP Implementation Nodal Agency, M/s PFC has been
requested to allow rollout of only
one module of ERP i.e. Project
Management under RDSS,
however, their response is still
awaited.
2 Page no 201 Vide Nigam has submitted the revised Capital Investment Plan for FY Complied
3 UHBVNL memo no 2023-24 as directed in HERC Tariff order dated 15.02.2023 with with.
and Ch- revised cost of Rs 1000 crore.
DHBVNL 51/RA/N/F
are directed -168 dated
to revise its 02.03.2023
Capital
expenditur
e plan for
FY2023-24
accordingly
and submit
the scheme
wise details

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
of the
proposed
expenditur
e to the
Commissio
n within
one month
of the
Order.
2 Page no 206 Does not relate to UHBVNL Does not
4 The relate to
Commissio UHBVNL
n observes
that the low
collection
efficiency in
five circles
of DHBVN
reflected
under
recovery of
revenue
and
attributes
to financial
losses on
account of
additional
borrowings
by the
licensees to
meet their
revenue
shortfall
besides
accumulati
on of arear
which in
turn may
convert into
bad debts.
In view of
the above,
the
Commissio
n directs
DHBVN to
improve
collection
efficiency in
above
circles by
plugging

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
loopholes
of revenue
leakage.
2 Page no 214 Vide The status of pending Non-AP connections is attached as Partially
5 DISCOMs memo no Annexure-I to IV and summarized as under: - Complied
are Ch- (a) As per SOP Regulations, prescribed timeline is 37 days for LT with
therefore 57/RA/F- connection & 78 days for HT connections However
directed to 173 Vol- for both New & EOL. there is
make all out (14) dated (b) SOP timelines exclude time taken by applicant in compliance. improveme
efforts to 09.05.2023 (c) Average delivery time & % delivery within SOP from 1st nt
release all January, 2023 to 31st March 2023 is as under: -
pending Type LT Supply (up to 50 KW) HT Supply (Above 50 KW)
connection Average % within Average % within
s within the delivery SOP delivery SOP
time frame Time timeline Time timeline
as specified New 19.34 days 97.18% 57.15 days 83.51 %
EOL 10.88 days 98.06 % 40.42 days 88.32 %
in
regulations (d) Pending overdue applications excluding pending on
in-vogue. compliance of demand notice on part of applicant ending
09.05.2023 is as under: -

Typ LT Supply (up to 50 KW), HT Supply (Above 50 KW)

e
Overd Load % Overd Load %
ue KW overd ue KW overd
ue ue
Ne 231 1307. 2.32% 25 139522 7.79%
w 4 .6

EOL 9 219.9 1.10% 21 30392. 6.36%

5
The connections are being released within SOP timelines and
there is negligible pendency of small number of overdue cases,
which are due to variety of factors which are peculiar to each case
such as ROW issue, requires augmentation, delay in self execution,
local system constraints, pending on part of consumer/delay in
processing etc. which are resolved and dealt accordingly.
2 Page no 223 Vide It is submitted that HERC directive is being complied with and the Complied
6 The memo no requisite information for FY 2022-23 (up to March 2023) has been with
Discoms Ch- submitted to HERC and HAREDA vide letter dated 01.05.2023
and other 48/RA/F-
obligated 173/Vol–
entities are (14) dated
directed to 03.05.2023
provide
requisite
information
to the State
Agency on
monthly
basis by
10th of
every
month for
the

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REQUIREMENT OF UHBVNL AND DHBVNL AND DISTRIBUTION & RETAIL SUPPLY TARIFF FOR THE FY 2024-25

# Directives Letter no. UHBVNL Reply Remarks

and date
previous
month to
enable the
State
Agency to
submit
quarterly
report to
the
Commissio
n.
2 Page no 229 Vide It is submitted that the direction of Hon’ble Commission is being Still some
7 The memo no. noted for compliance and the same will be proposed at the time of time is left
Commissio Ch- filing of ARR petition of FY 2024-25. for
n directs 46/RA/F- compliance
that in the 173/ Vol- . Deadline:
next ARR, 14 30.11.2023
the Discoms dated
will submit 01.05.2023
a tariff
proposal as
well; it may
not
necessarily
be for
increase or
decrease in
tariff(s) but
for
improveme
nt in tariff
design,
reduction in
the number
of category
/sub-
category,
re-
alignment
of demand
/ fixed
charges etc.
The
proposal
should
include its
impact on a
typical
consumer

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
1 UHBVNL and DHBVNL are directed to Vide It is humble submission to the Hon’ble Commission that, Nigam’s Financial Complied with
intimate, within one month from the memo Statement are being prepared as per Indian Accounting Standard. As per IND AS-
date of the present order, the details no Ch- 16 rule capital expenditure are being capitalized when assets is put to use.
of assets for which Capex were 54/SE/R Accordingly, the depreciation is determined on capitalized asset as per HERC MYT
incurred and depreciation claimed A-761 Regulation (Refer Note 1.7 of Audited Account of DHBVNL, Annexure- 1). Same
but remained stranded / un-utilized dated was claimed by the Nigam in True-up of FY 2021-22.
due to one reason or the other 28.04.2
including non-availability of 023.
associated lines/ equipment etc.
2 The licensee(s) must ensure that Vide It is submitted that, Nigam has noted the Hon’ble Commissions direction for Complied with
consumers are paid interest on their memo compliance and interest on the Advance Consumption Deposits shall be paid to
Advance Consumption Deposits duly no Ch- the consumer as per existing provision of HERC Regulation.
reflected in their energy bills for the 54/SE/
relevant month i.e. bill(s) issued in RA-761
the month of April / May dated
28.04.
2023
3 In view of the discrepancies in the AP Vide It is submitted that, M/s Parnat Engineers Pvt. Ltd. firm had calculated the T&DNot Complied
sales figures, the Commission directs Memo losses (based on empirical formulae) as 15.15%, 15.56% and 16.10 % for FY 2017- The reply is
that the MD DHBVNL will check the no. Ch- 18, 2018-19 and 2019-20 respectively. However, the losses of DHBVNL on AP not
figures of AP sales and input energy 113/SE feeders range between 8% to 9%. satisfactory as
and submit a report on running of AP /RA- does not
tube wells on non-AP feeders within 761 Further, following points are also submitted: address the
one month of issue of this order dated 1. Out of the total AP connections as on 31.03.2022, 26% of AP connections are observation.
besides reconciliation of figures as 23.08. unmetered.
per order. 2023 2. Defective meter on AP connections as on 31.03.2022 is 93393, which is 28% of
Total AP connections.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
Billings of these connections are done on provisional basis as per Sales Circular:
D-28/2013 (as per Hon’ble HERC directions issued vide memo no.
7011/HERC/T126 dated 13.12.2012 and order issued in case no. HERC/RA-01 of
2013 dated 06.06.2013).
3. During end of FY 2020-21, 10 sub- division were under migration to R-APDRP
system, which were not billed during this period. Further, with completion of
migration process, same were billed in FY 2021-22 (Annexure-A). The process
migration of all sub- divisions has been completed in March 2023
Consequently, during this period, the billed energy on AP feeders exceeds the
input energy.
The reason of AP consumption on Non AP feeder are as given below:-
a) 14175 no. of AP consumer with connected load of 107.1 MW were not
shifted from Non AP feeder due to unavailability of right of way
(Annexure-B).
2528 no. of AP consumer with connected load of 14.27 MW were temporary
shifted to Non AP feeders due to break down (Annexure-C).
4 The Commission had rationalized Vide DHBVNL has noted the above direction of the Hon’ble Commission. Collated Complied with
certain tariff category and classified memo energy sales and revenue data as per the merged categories shall be submitted
the same into HT and LT supply no Ch- to Hon’ble Commission at time of ARR filing.
depending on the voltage of at which 54/SE/
consumers in different categories RA-761
were taking supply. Hence, the same dated
practice shall continue. The Discoms, 28.04.
may collate data accordingly i.e. as 2023
per the merged categories instead of
the categories that have been
dispensed with
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
5 While resorting to bidding or calling Vide The direction of Hon’ble Commission has been noted. It is submitted that as per Complied with
for expression of interest for power memo HERC order, Practice is being followed by HPPC to contract the new source of
procurement the Discoms must no Ch- power supply under long term, medium term & short-term basis after comparing
ensure that the power under PPAs, 59/SE/ the landed cost of such power with the cost of power from state generating
already approved by the RA-761 station i.e. HPGCL.
Commission, materialises and also dated
the intra-State generator, subject to 16.05.
MoD in vogue are dispatched. 2023
However, it is reiterated that when
contracting a new source of power
supply the landed cost of such power
vis-à-vis cost of power from HPGCL’s
power stations shall be reckoned
with instead of MoD prepared on the
basis of variable/ fuel cost.
6 In case additional power, if required, Vide The direction of Hon’ble Commission has been noted. HPPC has filed petition on Complied with
may be met from power allocated to memo dated 06.04.2023 before HERC to seek approval to purchase power from
Haryana from the Central un- no Ch- unallocated quota of central generating stations in line with MoP order dated
allocated quota with prior approval 59/SE/
22.03.2023.
of the Commission. However, in case RA-761
of extreme emergency Discoms may dated
schedule power subject to ex-post 16.05.
facto approval of the Commission 2023
giving detailed justification, not later
than 15 days thereof.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
7 The licensees are again directed to Vide DHBVNL in present petition has projected employees cost for FY 2022-23 Complied with
analyse and explain the aberrations memo considering following factor:
in the MYT projections and that no Ch- i. Indexation Factor:
proposed in the present petition i.e. 54/SE/ Employee Expense of ARR year FY 2023-24 is computed by escalating previous
map all the factors for the increase RA-761 year employee expense by indexation factor. Following is the calculation of
including number of employees, dated indexation factor considered for escalation of employee cost:
contractual employees, DA, inflation 28.04. CPI Indices^ WPI Indices#
factor etc 2023 Month FY 2021-22 FY 2022-23* FY 2021-22 FY 2022-23*
April 345.9 367.8 132.0 152.3
May 347.3 371.5 132.9 155.0
June 350.5 372.1 133.7 155.4
July 353.7 374.1 135.0 154.0
August 354.2 375.0 135.9 153.1
September 355.1 378.1 136.0 152.1
October 359.7 - 137.4 -
November 362.0 - 140.7 -
December 361.2 - 143.7 -
January 360.3 - 143.3 -
February 360.0 - 143.8 -
March 362.9 - 145.3 -
Average 356.1 373.1 139.4 153.7
*Since, at time of Tariff Filing CPI & WPI for FY 22-23 is available up to
September, 2022 accordingly same is considered for computation of indexation
factor.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
^In September' 20, the base year of CPI has changed from 2001 to 2016 for
which linking factor of 2.88 as specified by the Labour Bureau of India is
considered for determination of indexation factor.
Source of CPI: http://www.labourbureaunew.gov.in/
#Source of WPI: https://eaindustry.nic.in/wpi_press_release_archive.asp
Considering above indices, Indexation Factor has been computed as per
Regulation 57.4 of HERC MYT Regulations, 2019, is as below:
Particulars WPI CPI Total
Weightage 0.45 0.55 1
Avg Indexation for FY 2022-23 153.7 373.1
Avg Indexation n (Index * Wt.) 69.1 205.2 274.3
Avg Indexation for FY 2021-22 139.4 356.1
Avg Indexation n-1 (Index *
62.7 195.8 258.6
Wt.)
Combined Inflation
6.10%
(Indxn/Indxn-1)
ii. Recruitment Plan of FY 2023-24:
DHBVNL has also considered the fact that Discom has planned to scale up its
existing infrastructure for robust distribution network. To upkeep the
manpower requirement for scaling of its existing infrastructure, 1699 Nos. of
manpower are planned to be recruited in FY 2023-24. Recruitment plan of
DHBVNL and its financial implication shared as Annexure -2. Further,
considering the basic salary of Rs. 25,500/- and applicable dearness allowance,
employee cost for these planned new recruitments is included over and above
the employee cost estimation explained in previous point.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
iii. Dearness Allowance:
Rate of Dearness Allowance applicable to Haryana Government employees as
notified by the Govt. of Haryana (Annexure-3) is shown in Table below:
With effect Haryana Government Notification No. & DA (%)
from Date
01/07/2019 4/1/2017-2 FR/32148 dated 25.11.2019 17%
01/07/2021 4/12019-1FR/26553 dated 23.12.2021 31%
01/01/2022 4/1/2019-1FR/0 dated 28.04.2022 34%
01/07/2022 4/3/2016-5FR/22747(2) dated 10.10.2022 38%
In view of above, the annual DA growth of 6% is considered in FY 2023-24.
Accordingly, DA rate of 44% is considered for projecting employee cost in FY
2023-24.
8 In case of DHBVNL, it is observed that Vide In this regard, it is submitted that working capital requirements has been fulfilled Complied with
the actual rate of interest of working memo from following sources:
capital for FY 2021-22 comes out to no Ch- 1. HVPNL Bonds with interest @ 8.62% PA.
be ~21%, as per the additional data 54/SE/ 2. State Bank of India Terms loans with rate of interest @ 6 M MCLR+0.20%.
submitted by the Nigam vide email. RA-761 3. Availing of WCDL & Cash credit limits from various Banks, the rate of interest
There is some discrepancy in the data dated charged by the Banks during FY 2021-22 is as under:
sheet as to inappropriate disclosure 28.04. Percentage of Interest rate charged
Sr.
of opening and closing balances of 2023 Name of Bank during FY
no.
the working capital loan accounts in WCDL CC Limit
the data sheet, leading to 1 Union Bank of 6.50- 3 M T. 7.20 1 Y MCLR
computation of incorrect actual rate India 6.90 Bill
of interest on working capital. In view 2 CANARA Bank 6.55- 1 M - -
of above, the Commission directs the 6.70 MCLR
Nigam to look into the reasons for
submitting incorrect data and report
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
the accurate the rate of interest paid 3 Bank of Baroda 6.90- 1 M 7.10- 1Y MCLR
by the licensee for the FY 2021-22 on 7.00 MCLR 8.00
working capital loans. Also, both the 4 Indian Bank 6.40- 1 M 7.30 1Y MCLR
Discoms to ensure that accurate and 7.05 MCLR
complete information is submitted 5 Central Bank of 6.55- 1 M 7.10 1Y MCLR
along with the ARR petitions every India 6.60 MCLR
year. 6 Punjab - - 9.80 3M MCLR
National Bank

Further, it is submitted that generally the requirement of working capital funds

during 1st half of the month (mainly for power purchase payments & payment
of salary to the employees) remain very high as compared to the revenue inflows
of DHBVNL. To meet with this enhanced requirements of fund, the working
capital limits from the banks is availed in order of merit of interest rates. The CC
limits once availed is recouped (again in order of merit of interest rate) when
inflow of cash is increased. In this way the CC limits/ working capital limits from
the Banks varies as per requirement of funds for a particular period in a month.
Hence, opening and closing balance in most of the CC accounts remain zero/ or
nominal. This practice is adopted over the year. Accordingly, Banks charge the
interest for the period of working capital availed by Nigam (which is generally in
between the month).

In view of above, it is submitted that the method of calculation of interest rate

based on the opening & closing balances of the working capital amounts in the
bank accounts may not present a real rate of interest charged by the Banks. The
Hon’ble Commission is requested to consider the above submission of DHBVNL.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
9 The Commission has noted with the Vide It is submitted that the Discoms have projected the power purchase cost for FY Complied with
concern that the average cost of memo 2023-24 excluding the unprecedented circumstance of increase in variable cost
power (without transmission cost) no Ch- due to blending of imported coal as per MoP directives and due to unavailability
for the FY 2023-24 has been 59/SE/
of power from APL, CGPL, Faridabad Gas & Khedar (during Q1) in FY 2022-23. Due
projected by the Discoms at Rs. 3.83 RA-761
/ Unit, while the same in the FY 2022- dated to unavailability of these sources and to provide continuous power in Haryana,
23 (up to December 2022 has been 16.05. power was purchased from alternate sources including short term and Exchange.
more than Rs.5/Unit. Moreover, the 2023 The prices in power exchange were on higher side during FY 2022-23.
landed cost of short-term power In the petition, the projections for availability of power have been undertaken
proposed for the consideration and only from long-term sources. Furthermore, it is submitted that impact of any
approval of the Commission is also variation in variable charges due to blending or external factors affecting GCV or
significantly higher and spills over to
fuel price could not be ascertained with accuracy at the time of filing of petition
the months, so far, considered as off
– peak months. and as such variable charges are captured through FSA only. Hence, Discoms
The Discoms are directed to examine found it appropriate to project the power purchase cost on normalized
the discrepancies in its power assumptions considering business as usual scenario with an understanding that
purchase cost vis-à-vis the cost the impact if any is to be taken on actual as per the MYT Regulations.
projected to bring out the facts that Further it is humbly submitted that variable charges during FY 2022-23 has the
would lead to reduction in cost of impact
power to the extent projected for the
of imported coal blending, which is significantly higher than the actual variable
ensuing financial year. A report
regarding the same may be charges of FY 2021-22. Hence, variable cost of FY 2022-23 cannot be used as the
submitted within a month from the base for the purpose of estimating the variable cost (Rs. Cr.) of FY 2023-24. Thus,
date of the present order. the variable charges (Rs/kWh) for the respective generating stations are
considered same as variable charges (Rs/kWh) of FY 2021-22 with 0% escalation.
Further, for the generating stations, whose variable charges were not available
on actual basis during FY 2021-22, variable charges of FY 2022-23 for the

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
respective generating stations are considered, for the purpose of estimation of
variable cost. The Fixed Cost estimation is carried out on pro-rata basis by
considering the Fixed Cost of FY 2022-23 for the respective generating station
with 0% escalation.
In addition, to the above, it is submitted that, no blending impact has been
considered in case of Thermal Generating Stations while estimating the Power
Purchase Cost of FY 2023-24 since the blending of imported coal is decided by
the MoP from time to time keeping in view the availability of domestic coal. The
power procurement has been considered keeping in view availability of power
at normative PLF from long term sources. Further, the petitioner in this present
ARR petition, has not considered any prior period expenses impact that may be
allowed by various courts of law in order to avoid over-estimation in the overall
Power Purchase Cost.
10 The licensee needs to exercise proper Vide It is submitted that the capital expenditure works are being monitored by Nigam Complied with
monitoring of scheme wise execution memo Officials/Officers at the highest level. The head-wise execution of capital works
of capital works and control over the no. Ch- and control over the head-wise expenditure as approved by the Commission are
item wise expenditure approved by 99/SE/R supervised and reviewed by the Nigam Officers on a regular basis. The capex is
the Commission as per Regulation A-761 controllable element of ARR as per Regulation 8.3.8 (b) of HERC MYT Regulations,
8.3.3 (b) of the Haryana Electricity dated 2019. Further and barring unforeseen circumstances, Nigam takes concerted
Regulatory Commission (Terms and 04.08.2 efforts to ensure that actual capital expenditure is as close to the approved
Conditions for Determination of 023 capital expenditure as possible.
Tariff for Generation, Transmission,
Wheeling, and Distribution & Retail
Supply under Multi Year Tariff
Framework) Regulations, 2019.
11 Both the licensees are further Vide The Capex plans as approved in the Tariff Order for FY 2023-24 is regulated by Complied with
directed that they shall regulate their memo Nigam as per the direction of the Hon’ble Commission. Further, the Nigam, being
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
capital expenditure plans for FY no. Ch- a regulated entity, follows the HERC MYT Regulations, 2019 and its amendments
2023-24 as per Regulations 9.7 to 99/SE/R thereof. The capital investment plan envisaged by Nigam is also shared with
9.12 of the Haryana Electricity A-761 Genco and Transco in due time in order to create sync between the investments
Regulatory Commission (Terms and dated proposed by all utilities. It will also be ensured that any additional capital
Conditions for Determination of 04.08.2 expenditure incurred due to time over-run or unapproved schemes, or changes
Tariff for Generation, Transmission, 023 shall not be considered in capital expenditure to be claimed during true-up
Wheeling, and Distribution & Retail without any reasonable justification and the same shall be subject to approval
Supply under Multi Year Tariff from the Hon’ble Commission.
Framework) Regulations, 2019.
12 The Commission again directs the Vide Status of losses of all urban feeders above 25% and that of Rural feeders above Partially
DISCOMs to reduce AT&C losses of all memo 50% as on March, 2023, compared to FY 2021-22 is as below: complied with
urban feeders below 25% and that of no Ch- FY 2022-23 Although
FY 2021-22
Rural feeders below 50% in FY 2022- 59/SE/ (as on there is
Year (as on
23 and to submit the Status Report RA-761 31.03.2023 improvement
31.03.2022)
after 2 months of the order dated ) but the
16.05. Urban Feeder(s) feeders with
2023 Total Feeders 973 996 higher losses
Feeders with losses > 25% 28 21 are still there.
Feeders with losses > 25% (in %age) 2.88% 2.11% More effort
Rural Feeder(s) required to
Total Feeders 1127 1154 make the
Feeders with losses >50% 279 227 count Nil
Feeders with losses >50% (in %age) 24.76% 19.67%

Circle-wise status of feeder losses of all urban feeders above 25% and Rural
feeders above 50% as on March, 2023 is as below:

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
Circle RDS Feeder Urban Feeder
Total RDS RDS feeder RDS feeder Total Urban Urban
Feeder above 50% above 50% Urban Feeder Feeder
loss loss (in %) Feeder above above
25% loss 25% loss
(in %)
Hisar 137 58 42% 102 2 2%
Bhiwani 160 24 15% 56 0 0%
Sirsa 174 0 0% 60 1 2%
Fatehabad 119 15 13% 46 1 2%
Jind 150 83 55% 47 10 21%
Faridabad 32 0 0% 236 0 0%
Palwal 114 47 41% 36 6 17%
Gurugram-I 53 0 0% 116 0 0%
Gurugram-
32 0 234 1
II 0% 0%
Narnaul 93 0 0% 28 0 0%
Rewari 90 0 0% 35 0 0%
Total 1154 227 20% 996 21 2%

It is pertinent to be note that DHBVNL is implementing two major loss reduction

schemes namely:
C. Mhara Gaon Jagmag Gaon Scheme (MGJG) for Rural feeders
D. Loss Reduction Plan (LRP) for Urban feeders
DHBVNL’s Action Plan to reduce T&D losses:
• Detection of theft.
• Mass drive to replace the defective & electro-mechanical meters:

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
• Relocation of meters outside consumers premises, feeder wise, and
effective sealing thereof.
• Replacement of ACSR with Cable in theft prone area / colonies.
• Providing reference meters in the colonies / housing complexes (societies).
• Cross checking of meter readings taken by MRBD Agency.
• Checking of MDI of the temporary connections and MF of HT / LT
Consumers.
• Creation of centralized cell to audit the accounts of Open Access Consumers.
• Operationalization of technical audit to keep check on the quality & quantity
of material & workmanship of the works.
• Fixation of targets at Sub-Division level to improve the Billing efficiency &
monitoring thereof.
• Implementation of LRP Scheme activities in Urban feeders
• Implementation of Mahara Gaon Jagmag Gaon Scheme activity in Rural
feeders.
It is humble submission to the Hon’ble Commission that, as of now the MGJY and
LRP activity has been implement in most of the feeders. Currently, MGJY activity
in 215 rural feeders are under progress and work under 66 rural feeders are yet
to start. Nigam officials is facing resistance in implementing MGJY works in some
villages, which has resulted in delay in completion of work under these feeders.
13 The Commission again directs the Vide Distribution damage rate (excluding DT under warranty period) in FY 2022-23 is Partially
licensee to bring down the memo 5.87% in Rural which is below the limit of 6% as prescribed by the HERC in SOP Complied
distribution transformer damage rate no Ch- regulation. Further, in Urban area Distribution damage rate is 3.36%, which is more effort
below the prescribed limits in FY 59/SE/ marginally higher than the limit of 3% as prescribed by the HERC in SOP required to be
2022-23 and FY 2023-24. Any RA-761 regulation. put in to
slippage on account of the timeline dated Further, to reduce/control the damage rate the following activities are being reduce the
shall lead to penalty as deemed fit carried out:

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
and appropriate by the Commission 16.05. • Capacity augmentation of overload distribution transformers. transformer
as per various provisions of the Act 2023 • Vigilance activity i.e. theft detections are being caried out, to protect the damage rate.
and Regulations framed thereunder. overloading of transformer from kundi connections.
Further, Commission directs the • Balancing load of Distribution Transformer.
licensee to provide the action plan The Nigam is also focusing on regular maintenance activity like- preventive
and the action taken to reduce rate maintenance of distribution transformer to reduce earthing fault and Toping-up
DT damage during FY 2022-23 and FY of Transformer oil.
2023-24.
14 DHBVNL is again directed to clear the Vide Total Defective meter (Non-AP connection) in DHBVNL as on 31.03.2023 is Complied with
backlog of defective metering and to memo 59,141 which is around 1.57% of Total non-AP connection of 37,69,560 as on
ensure that at no point of time the no Ch- 31.03.2023.
percentage of defective meters 59/SE/
exceeds 2% limit as per SOP RA-761
regulations in vogue dated
16.05.
2023
15 The Commission directs DISCOMs Vide Status of electromechanical meters as on 31.03.2023 is as below: Partially
especially DHBVNL to replace all memo No. of electromechanical meters as on complied with
electromechanical meters shown no Ch- Meter category 31.03.2023
pending for replacement and submit 59/SE/ Rural Urban AP Total
compliance report within 3 months RA-761 Single Phase Meters 44,774 - 0 44,774
from date of this order. dated Three Phase Meters - - 30,232 30,232
16.05. Total 44,774 - 30,232 75,006
2023
16 DISCOMs are directed to expedite Vide Total Smart meters proposed to be installed in DHBVNL: Partially
the Installation of Smart Metering memo Type of Smart Proposed to be installed Total Smart meters to complied with
Project already undertaken to ensure no. Ch- meter Gurugram Faridabad be installed
the competition of 99/SE/
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
RA-761 A B C=A+B
project within the time lines of dated Single Phase
210361 106823 317184
agreement executed between EESL 04.08. Meter
and DISCOMs 2023 Three Phase
161551 14257 175808
Meter
Three Phase LT
5001 2007 7008
CT Meter
Total 376913 123087 500000

Status of Smart Meter installation in Gurugram as on 19.07.2023:

Type of Smart meter To be installed Total Balance
installed
Single Phase Meter 1,78,387 1,56,141 22,246
Three Phase Meter 1,34,920 99,927 34,993
Total 3,13,307 2,56,068 57,239
• Balance 63606 meters against scope of work in Gurugram town have been
reserved for release of New service connections.

Status of Smart Meter installation in Faridabad:

• EESL was scheduled to start consumer Indexing and meter installation was
scheduled from 1st Feb'23. However, work could not be started, due to
suspension of work by system Integrator M/s L&T on account of
outstanding dues/payment issue with M/s EESL.
• The work was later recommenced by M/s L&T form April’23 month in
Gurugram but with reduced labour, and same continued till June 2023.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
After issuance of D.O. letter no. 75/SCP-102 dated 03.07.2023 by W/MD,
DHBVNL to CEO, EESL, M/s L&T has agreed to deploy manpower in Faridabad
town and started consumer indexation from 18.07.23 and further meter
installation will commence once the approval of Consumer Indexation.

17 Further, DISCOMs to submit status of Vide It is submitted that Nigam is targeting to implement smart metering under RDSS Not Complied
RFP/NIT along with their detailed memo scheme. As per approved action plan of RDSS, the details of smart consumer Latest status
plan regarding replacing of no. Ch- meter to be installed are as under please: - submitted but
conventional energy meters by 99/SE/ action still
prepaid smart meters within two RA-761 Name of pending.
DHBVNL
months of issuance of this Tariff dated utility
Order. 04.08. Phase – I Phase – II
2023 Sr. No. (upto December, (upto March, Total
2023) 2025)
Consumer 41,65,6
19,67,122 21,98,496
Meter 18
1,28,34
DT Meter 1,28,340 -
0
Feeder
6,604 - 6,604
Meter
43,00,5
Total 21,02,066 21,98,496
62

• For implementation of distribution infrastructure works and pre-paid

smart metering works, MoP has circulated Standard Bidding Documents which
are to be followed, mandatorily by all the States for inviting bids. THE SBD inter-

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
alia stipulates implementation of this project in TOTEX mode wherein MDM shall
be an integral part of ecosystem of AMISP.
• In this regard, Haryana DISCOMs has certain reservations on the TOTEX
mode & other approach w.r.to implementation of smart metering. The following
proposal of Haryana DISCOMs for implementation of Smart Metering projects
under RDSS has been forwarded via email dated 21.12.2022 to Ministry by PFC by
MD, DHBVNL/UHBVNL: -
o The ownership of complete system rests with AMI-Service Provider
instead of State which may jeopardize the entire revenue cycle of the utilities
causing loss to state exchequer in the event of dispute.
o The Meter Data Management System (MDMS) is in the consolidated
package of AMI-Service Provider. The multiplicity of MDMS in various packages
shall lead to increased financial burden towards license cost, customization &
configuration cost of MDM and increase in the efforts for integration with existing
billing engine and other internal & external IT systems and increase in the
complexity in the O&M and change management of the system.
o Provision of Direct Debit Facility as a payment mechanism to AMI – Service
Provider. The provision of Direct Debit facility can affect the cash flow of the
Discom and there will be no control over the payments to be made to the AMI-
Service Provider.
o The Ministry of Power has mandated universal approach in the
implementation of AMI project with disregard to the practical conditions and
prior experience of utilities in the various IT/OT projects Haryana is already in
advanced stage of installation of 1 million smart meters. The enabling billing
system with inbuilt MDM is already available for rolling out large scale
implementation of smart metering initiatives.
o TOTEX mode of smart metering implementation as mandated under RDSS
scheme has certain deficiencies viz. no ownership with respect to infra/systems
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
of Discoms, vendor locking for entire duration of the project, complex/multiplicity
of IT integrations with multiple MDMS, additional/duplicate expenditure on
procurement of new MDMS.
o Haryana Discoms intend to go for complete CAPEX or Hybrid mode of
project implementation, wherein the ownership of entire Infra/systems shall
remain with Discoms and existing MDMS available with Discoms could be
leveraged for smooth IT integrations. The proposed models are also suitable for
prospective AMI-SPs keeping in view their huge capital investments.
o The State Govt. has the opinion of not aligning with the mandate of MOP,
GOI for implementation of smart metering project on TOTEX mode.
Keeping in view the challenges faced in EESL project on DBFOOT model, Haryana
Discoms are pursuing the matter with MoP to allow the prepaid smart metering
implementation under RDSS on CAPEX Hybrid financing model to retain the
ownership of AMIl application as long-term vendor lock-in will create a
monopolistic situation favoring AMI-SPs who may compromise with meter quality
and ignore Discom/Consumer's genuine concerns The decision for floating of
tenders will be finalized once mode of implementation is decided.
In this regard, meeting was held on 07/06/2023 under chairmanship of Hon'ble
Chief Minister, GoH for deciding the approach/mode of implementation of Smart
Metering. Above issues were further discussed with various stakeholders (i.e.
AMI-SPs, Meter manufacturer, CSPs, etc.) in meeting dated 30/06/2023 held
under the chairmanship of Hon'ble Power Minister, GoH .
18 The commission directs DISCOMs: - Vide It is submitted that, the provisional billing of DHBVNL has reduced to 3.67% in Partially
iv. To improve efficiency in the memo month of January, 2023, in line to the direction of the Hon’ble Commission vide Complied
meter reading activities including no Ch- its interim order dated 10.08.2022 to reduce the provisional billing up to 4% in
billing. 54/SE/R first phase.
v. To reduce number of bills A-761
rendered on provisional basis. dated
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
vi. There should be no bill rendered 28.04.2 The provisional billing of DHBVNL is expected to go down further, owing to efforts
on average basis for more than 2 023 being made. The Status of Provisional billing for the month of January 2023,
billing cycles failing which February 2023 and March 2023 is shared as Annexure -4.
consumer shall be entitled to
claim compensation.

19 It may be noted that in case batteries Vide It is submitted that Nigam is in process of floating RFP for setting up of 2 no. of Complied with
are installed by the Discoms at their memo 5MWh Grid integrated Battery Energy Storage System (BESS) under DBOOT
sub-stations and the same are no Ch- model at 33kv sub-station of DHBVNL. Further, it is submitted that BESS is setup
charged during off-peak hours so that 54/SE/ with the prime objective of making the energy storage facility available to
the stored power can be injected RA-761 DHBVNL for “Stored Energy” of BESS on an “On Demand” basis. The BOD in
back into the grid during peak hours dated meeting dated 28th September, 2022 has approved the general term and
to bridge any demand-supply gap, 28.04. condition, along with scope of BESS approved scope is submitted as Annexure -
the same shall be counted towards 2023 5 for your kind reference.
fulfilment of storage RPO.

20 Page 185 Complied with

The petitioners are directed to Vide It is submitted to the Hon’ble Commission that the Nigam has noted the
ensure that supply of power to AP / memo direction for compliance. Further, It is submitted that Gov. of Haryana is
any categories of consumers, where no. Ch-
regularly releasing the subsidy to Nigam.
the State Government has 99/SE/
committed a subsidized tariff, is RA-761
strictly in accordance with section 65 dated
of the Electricity Act, 2003. 04.08.
2023

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date

21 Page no 186 Vide Detail of the amount collected by the distribution licensee in the FY 2022-23 by
The Discoms are directed to file memo way of MMC is shown in Table below:
revenue realised from MMC in the FY no Ch- Revenue Realized from MMC
Circle Name Count
2022-23 within one month from the 59/SE/ in FY 2022-23
date of this order RA-761 Bhiwani 221872 130801419.00
dated Faridabad 114356 67117949.00
16.05. Fatehabad 113923 70239563.00
2023 GURUGRAM -1 39771 38995482.00
GURUGRAM -2 21208 31196612.00
Hisar 228450 125974534.00
Jind 353158 191881332.00
Narnaul 99312 59576095.00
Palwal 198757 77460618.00
Rewari 85181 49230577.00
Sirsa 93156 62816063.00
Grand Total 1569144 905290244.00
22 Page no 195 Does not relate to DHBVNL
UHBVNL is directed to give the
justification of nil expenditure
against the approved capex and to
adhere to the Regulation
meticulously.
23 Page no 201 Vide The revised CAPEX plan as per directions of the Hon’ble Commission is shared as Complied with
UHBVNL and DHBVNL are directed to memo Annexure -6.

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
revise its Capital expenditure plan for no Ch-
FY2023-24 accordingly and submit 54/SE/R
the scheme wise details of the A-761
proposed expenditure to the dated
Commission within one month of the 28.04.2
Order. 023

24 Page no 206 Vide Detail related collection efficiency of DHBVNL for FY 2022-23 is shared as below. Complied with
The Commission observes that the memo Further, it is submitted that DHBVNL is putting all its efforts to improve its
low collection efficiency in five circles no Ch- collection efficiency in all operative circles.
of DHBVNL reflected under recovery 113/SE/
of revenue and attributes to financial RA-761 Collection efficiency (in %)
Name of Circle
losses on account of additional dated FY 2022-2023 (upto 03/2023)
borrowings by the licensees to meet 23.08.2 FARIDABAD 100.89
their revenue shortfall besides 023 PALWAL 96.65
accumulation of arear which in turn
GURUGRAM-1 93.09
may convert into bad debts.
GURUGRAM-2 95.32
In view of the above, the Commission
NARNAUL 102.86
directs DHBVNL to improve collection
REWARI 101.76
efficiency in above circles by plugging
BHIWANI 100.42
loopholes of revenue leakage.
HISAR 94.34
FATEHABAD 100.42
SIRSA 98.43
JIND 95.60
DHBVNL 97.13

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
25 Page no 214 Vide Nigam has noted the direction of Hon’ble Commission for Compliance. Further, Partially
DISCOMs are therefore directed to memo it is submitted that release of connection is a continues process and DHBVNL Complied with
make all out efforts to release all no Ch- assure to release of all pending Connections, with in stipulated time. Further However,
pending connections within the time 99/SE/R status of release of Non-AP Connection for FY 2021-22 and FY 2022-23 is there is
frame as specified in regulations in- A-761 submitted in Table below: improvement
vogue. dated FY 2021-22:
04.08.2 New
Disposed Off Pending as
023 Pending at Application
During 2021- on
31.03.2021 received 2021-
22 31.03.2022
22
Category
No. of
No. of No. of No. of
Load Load Load Appli Load
Applica Applic Applic
(KW) (KW) (KW) catio (KW)
tion ation ation
n
1582 25936 7529
74 116 176415 149 41
BDS 44 6 2
Bulk 1806 22313
5 52 212289 48 9 7223
Supply 9 5
DMRC 1 15000 1 15000
Domesti 6550 2215 184056 2220 18611 1170 4496
12273
c (DS) 3 14 45 87 05 0 8
ECS 109 11569 101 10893 8 676
FPO 32 431 590 7713 497 6118 125 2031
HT 6454 37529 2510
124 788 561824 799 113
Industry 7 2 78
Indepen 1000
18 111208 13 11132 5
dent 76

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
Hording
or
Decorati
ve Light
LI 2 24 817 17677 813 17466 6 235
LT 10224
333 7325 4938 102090 4939 332 7169
Industry 5
Non-
1469 5119 5102 91851 1151
Domesti 2679 886723 2856
78 8 1 9 82
c (NDS)
Public
1275
Water 106 6712 1883 60771 1656 54732 333
1
Work
Railway 1350
1 4 55550 5 69050
Traction 0
Saubhag 1038
867 1385 9936 15230 15949 423 666
ya 0
Street
9 68 451 6567 416 5766 44 868
Light
Grand 4827 2924 408119 2929 39457 1599 6182
16505
Total 86 15 0 25 65 5 10
FY 2022-23:
Category Pending at New Disposed Off Pending as on
31.03.2022 Application During 2022- 31.03.2023
received 2022- 23
23

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
No. of Load No. of Load No. of Load No. of Load (KW)
Applicati (KW) Applica (KW) Applica (KW) Applic
on tion tion ation
BDS 41 75292 95 169948 102 19831 34 46927
3
Bulk 9 7223 35 20821 40 19448 4 8596
Supply
DMRC 3 14000 3 14000 0 0
Domestic 11700 44963 23685 985515 23821 98141 1034 49065
(DS) 7 5 2 2
ECS 8 676 291 25367 274 19797 25 6247
FPO 125 2031 771 9956 828 11144 68 842
HT 113 25107 990 580944 927 60501 176 227008
Industry 8 4
Indepen 5 10007 17 6244 22 10632 0 0
dent 6 0
Hording
or
Decorati
ve Light
LI 6 235 1098 32529 1091 32529 13 235
LT 332 7170 4880 99374 4911 99422 301 7122
Industry
Non- 2856 11518 56215 803961 56540 81043 2531 108710
Domestic 2 3
(NDS)

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
Public 333 12751 1692 46739 1838 51340 187 8150
Water
Work
Railway 1 500 1 500 0 0
Traction
Saubhag 423 667 6134 9215 6449 9729 108 152
ya
Street 44 868 568 7032 564 6804 48 1096
Light
Grand 15995 61821 30964 281214 31180 29662 1383 464149
Total 0 7 4 5 04 7
26 Page no 223 Vide Nigam has noted the direction of Hon’ble Commission for Compliance. Complied with
The Discoms and other obligated memo
entities are directed to provide no Ch-
requisite information to the State 99/SE/R
Agency on monthly basis by 10th of A-761
every month for the previous month dated
to enable the State Agency to submit 04.08.2
quarterly report to the Commission. 023
27 Page no 229 Vide Nigam has noted direction for Compliance and shall submit a Tariff Proposal in Not complied
The Commission directs that in the memo Next Tariff Filing.
next ARR, the Discoms will submit a no Ch-
tariff proposal as well; it may not 59/SE/
necessarily be for increase or RA-761
decrease in tariff(s) but for dated
improvement in tariff design, 16.05.
reduction in the number of category 2023

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. Directives issued in the present Letter DHBVNL Reply Remarks

no. HERC ARR / Tariff order dated no. and
30.03.2022: date
/sub-category, re-alignment of
demand / fixed charges etc. The
proposal should include its impact on
a typical consumer.

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SUPPLY TARIFF FOR THE FY 2024-25

Directive Compliance- UHBVNL

Directive Compliance- UHBVNL

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
1 UHBVNL and Vide memo It is submitted to the Hon'ble Commission that the assets for which capex is Complied with
DHBVNL are directed no Ch-20 F- incurred are being utilized at their fullest capacity, therefore no assets are As stated in the
to intimate, within 173 Vol-14 dt stranded / un-utilized. The depreciation is claimed as per the HERC MYT reply by UHBVNL,
one month from the 13.03.2023 Regulations 2019 and its amendments thereof. there is no asset for
date of the present which Capex were
order, the details of incur and
assets for which depreciation
Capex were incurred claimed but
and depreciation remained stranded
claimed but / un-utilized.
remained stranded /
un-utilized due to
one reason or the
other including non-
availability of
associated lines/
equipment etc.
2 The licensee(s) must Vide memo It is submitted that the compliance of directive of HERC has been made and the Complied with
ensure that no Ch- interest on ACD is initiated / reflected in consumer bills w.e.f. 1st April/2023
consumers are paid 48/RA/F-
interest on their 173/Vol–(14)
Advance dated
Consumption 03.05.2023
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
Deposits duly
reflected in their
energy bills for the
relevant month i.e.
bill(s) issued in the
month of April / May
3 In view of the Does not relate to UHBVNL Does not relate to
discrepancies in the UHBVNL
AP sales figures, the
Commission directs
that the MD DHBVNL
will check the figures
of AP sales and input
energy and submit a
report on running of
AP tube wells on
non-AP feeders
within one month of
issue of this order
besides
reconciliation of
figures as per order.
4 The Commission had Vide memo UHBVNL is already classified LT & HT category as per merged categories of Complied with
rationalized certain no Ch- tariff and compiling the data accordingly from F.Y. 2022-23 onwards.
tariff category and 11/RA/F-173
classified the same Vol-14 dt.
into HT and LT supply 07.03.2023
depending on the
voltage of at which
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
consumers in
different categories
were taking supply.
Hence, the same
practice shall
continue. The
Discoms, may collate
data accordingly i.e.
as per the merged
categories instead of
the categories that
have been dispensed
with
5 While resorting to Vide memo The direction of Hon’ble Commission has been noted. It is submitted that as per Complied with
bidding or calling for no Ch- HERC order, Practice is being followed by HPPC to contract the new source of
expression of 36/RA/F- power supply under long term, medium term & short-term basis after comparing
interest for power 173/Vol-(14)
the landed cost of such power with the cost of power from state generating
procurement the dated
Discoms must ensure 28.04.2023 station i.e. HPGCL.
that the power under
PPAs, already
approved by the
Commission,
materialises and also
the intra-State
generator, subject to
MoD in vogue are
dispatched.
However, it is
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
reiterated that when
contracting a new
source of power
supply the landed
cost of such power
vis-à-vis cost of
power from HPGCL’s
power stations shall
be reckoned with
instead of MoD
prepared on the
basis of variable/ fuel
cost.
6 In case additional Vide memo The direction of Hon’ble Commission has been noted. HPPC has filed a petition Complied with
power, if required, no Ch- dated 06.04.2023 before HERC to seek approval to purchase power from
may be met from 36/RA/F- unallocated quota of central generating stations in line with MoP order dated
power allocated to 173/Vol-(14) 22.03.2023.
Haryana from the dated
Central un-allocated 28.04.2023
quota with prior
approval of the
Commission.
However, in case of
extreme emergency
Discoms may
schedule power
subject to ex-post
facto approval of the
Commission giving
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
detailed justification,
not later than 15
days thereof.
7 The licensees are Vide memo It is submitted that the projections for ARR year i.e., FY 2023-24 are done as per Complied with.
again directed to no Ch- the Haryana Electricity Regulatory Commission (Terms and Conditions for
analyse and explain 27/RA/F- Determination of Tariff for Generation, Transmission, Wheeling and Distribution
the aberrations in 173/vol (14) & Retail Supply under Multi Year Tariff Framework) Regulations, 2019 and its
the MYT projections dated amendment thereof.
and that proposed in 12.04.2023 The employee expense for ARR year is calculated by considering the revised
the present petition estimated employee expenses for APR year and inflation factor i.e., 6.10%, along
i.e. map all the with the dearness allowance of 8% is considered, which is additionally disbursed
factors for the by the government of Haryana in the APR year, the same is indexed for
increase including calculation of corresponding expenses for ARR year.
number of The MYT projections done taking actual employee expenses of FY 2018-19 and
employees, escalating it @ 4% to arrive at the base year value for the MYT Control Period.
contractual The base year employee expenses are indexed with inflation factor of 4.66% to
employees, DA, project the employee expenses of UHBVNL for ensuing years of the MYT Control
inflation factor etc Period.
UHBVNL in present petition has projected employees cost for FY 2023-24
considering following factor:
i. Indexation Factor:
Employee Expense of ARR year (FY 2023-24) is computed by escalating previous
year employee expense by indexation factor. Following is the calculation of
indexation factor considered for escalation of employee cost:
CPI Indices^ WPI Indices#
Month FY 2021-22 FY 2022-23* FY 2021- FY 2022-
22 23*
April 345.9 367.8 132.0 152.3

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
May 347.3 371.5 132.9 155.0
June 350.5 372.1 133.7 155.4
July 353.7 374.1 135.0 154.0
August 354.2 375.0 135.9 153.1
September 355.1 378.1 136.0 152.1
October 359.7 - 137.4 -
November 362.0 - 140.7 -
December 361.2 - 143.7 -
January 360.3 - 143.3 -
February 360.0 - 143.8 -
March 362.9 - 145.3 -
Average 356.1 373.1 139.4 153.7

*Since, at time of Tariff Filing CPI & WPI for FY 22-23 is available up to
September, 2022 accordingly same is considered for computation of indexation
factor.
^In September' 20, the base year of CPI has changed from 2001 to 2016 for
which linking factor of 2.88 as specified by the Labour Bureau of India is
considered for determination of indexation factor.
Source of CPI: http://www.labourbureaunew.gov.in/
#Source of WPI: https://eaindustry.nic.in/wpi_press_release_archive.asp
Considering above indices, Indexation Factor has been computed as per
Regulation 57.4 of HERC MYT Regulations, 2019, is as below

Particulars WPI CPI Total

Weightage 0.45 0.55 1
Avg Indexation for FY 153.7 373.1
2022-23
Avg Indexation n (Index * 69.1 205.2 274.3
Wt.)
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
Avg Indexation for FY 139.4 356.1
Avg Indexation n-1 (Index 62.7
2021-22 195.8 258.6
Combined
* Wt.) Inflation 6.10%
(Indxn/Indxn-1)
ii. Recruitment Plan:
UHBVNL has also considered the fact that Discom has planned to scale up its
existing infrastructure & strengthen IT backbone for robust distribution
network. To upkeep the discom with rapid changing technology in distribution
sector specialized manpower
needs to be recruited from time to time.
Further, considering the basic salary of Rs. 25,000/- and applicable dearness
allowance, employee cost for new recruitments is included over and above the
employee cost estimation explained in previous point.
iii. Dearness Allowance:
Rate of Dearness Allowance applicable to Haryana Government employees as
notified by the Govt. of Haryana is show in table below:
With effect Haryana Government Notification No. &
DA (%)
from Date
01/07/2019 4/1/2017-2 FR/32148 dated 25.11.2019 17%
01/07/2021 4/12019-1FR/26553 dated 23.12.2021 31%
01/01/2022 4/1/2019-1FR/0 dated 28.04.2022 34%
4/3/2016-5FR/22747(2) dated
01/07/2022 38%
10.10.2022
The annual DA growth of 8% is considered in FY 2023-24.
As seen from above, the variation in employee expense as estimated at the time
of MYT projections and ARR projection is basically due to inflation factor and DA
payout by Government of Haryana.
8 In case of DHBVNL, it Does not relate to UHBVNL Does not relate to
is observed that the UHBVNL

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
actual rate of
interest of working
capital for FY 2021-
22 comes out to be
~21%, as per the
additional data
submitted by the
Nigam vide email.
There is some
discrepancy in the
data sheet as to
inappropriate
disclosure of opening
and closing balances
of the working
capital loan accounts
in the data sheet,
leading to
computation of
incorrect actual rate
of interest on
working capital. In
view of above, the
Commission directs
the Nigam to look
into the reasons for
submitting incorrect
data and report the
accurate the rate of
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
interest paid by the
licensee for the FY
2021-22 on working
capital loans. Also,
both the Discoms to
ensure that accurate
and complete
information is
submitted along with
the ARR petitions
every year.
9 The Commission has Vide memo It is submitted that the Discoms have projected the power purchase cost for FY Complied with
noted with the no. Ch- 2023-24 excluding the unprecedented circumstance of increase in variable cost
concern that the 55/RA/F-173 due to blending of imported coal as per MoP directives and due to unavailability
average cost of Vol-14 of power from APL, CGPL, Faridabad Gas & Khedar (during Q1) in FY 2022-23.
power (without dt. Due to unavailability of these sources and to provide continuous power in
transmission cost) 09.05.2023 Haryana, power was purchased from alternate sources including short term and
for the FY 2023-24 Exchange. The prices in power exchange were on higher side during FY 2022-23.
has been projected In the petition, the projections for availability of power have been undertaken
by the Discoms at Rs. only from long-term sources. Furthermore, it is submitted that impact of any
3.83 / Unit, while the variation in variable charges due to blending or external factors affecting GCV
same in the FY 2022- or fuel price could not be ascertained with accuracy at the time of filing of
23 (up to December petition and as such variable charges are captured through FSA only. Hence,
2022 has been more Discoms found it appropriate to project the power purchase cost on normalized
than Rs.5/Unit. assumptions considering business as usual scenario with an understanding that
Moreover, the the impact if any is to be taken on actual as per the MYT Regulations.
landed cost of short- Further, it is humbly submitted that variable charges during FY 2022-23 has the
term power impact of imported coal blending, which is significantly higher than the actual
proposed for the variable charges of FY 2021-22. Hence, variable cost of FY 2022-23 cannot be
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
consideration and used as the base for the purpose of estimating the variable cost (Rs. Cr.) of FY
approval of the 2023-24. Thus, the variable charges (Rs/kWh) for the respective generating
Commission is also stations are considered same as variable charges (Rs/kWh) of FY 2021-22 with
significantly higher 0% escalation. Further, for the generating stations, whose variable charges were
and spills over to the not available on actual basis during FY 2021-22, variable charges of FY 2022-23
months, so far, for the respective generating stations are considered, for the purpose of
considered as off – estimation of variable cost. The Fixed Cost estimation is carried out on pro-rata
peak months. basis by considering the Fixed Cost of FY 2022-23 for the respective generating
The Discoms are station with 0% escalation.
directed to examine In addition, to the above, it is submitted that, no blending impact has been
the discrepancies in considered in case of Thermal Generating Stations while estimating the Power
its power purchase Purchase Cost of FY 2023-24 since the blending of imported coal is decided by
cost vis-à-vis the cost the MoP from time to time keeping in view the availability of domestic coal. The
projected to bring power procurement has been considered keeping in view availability of power
out the facts that at normative PLF from long term sources. Further, the petitioner in this present
would lead to ARR petition, has not considered any prior period expenses impact that may be
reduction in cost of allowed by various courts of law in order to avoid over-estimation in the overall
power to the extent Power Purchase Cost.
projected for the
ensuing financial
year. A report
regarding the same
may be submitted
within a month from
the date of the
present order.
10 The licensee needs Vide memo It is submitted that the capital expenditure works are being monitored by Nigam Complied with
to exercise proper no Ch-20 F- Officials at the highest level. The scheme-wise execution of capital works and As per tariff order
monitoring of control over the item-wise expenditure as approved by the Commission are dated 15.02.2023,
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
scheme wise 173 Vol-14 dt supervised and reviewed by the Nigam Officers on a regular basis. The capex is for the true-up year
execution of capital 13.03.2023 controllable element of ARR as per Regulation 8.3.8 (b) of HERC MYT 2021-22, UHBVNL
works and control Regulations, 2019. Further and barring unforeseen circumstances, Nigam takes was able to
over the item wise concerted efforts to ensure that actual capital expenditure is as close to the incurred Capex of
expenditure approved capital expenditure as possible. Rs. 947.37 Cr.
approved by the against approved
Commission as per capex of Rs. 950 Cr.
Regulation 8.3.3 (b) Therefore, the
of the Haryana actual capital
Electricity Regulatory expenditure for
Commission (Terms 2021-22 was very
and Conditions for close to the
Determination of approved
Tariff for Generation, expenditure.
Transmission,
Wheeling, and
Distribution & Retail
Supply under Multi
Year Tariff
Framework)
Regulations, 2019.
11 Both the licensees Vide memo The Capex plans as approved in the Tariff Order for FY 2023-24 is generally and Complied with
are further directed no Ch- will be regulated by Nigam as per the direction of the Hon'ble Commission. Licensee assured to
that they shall 20/RA/F-173 Further, the Nigam, being a regulated entity, follows the HERC MYT Regulations, regulate the Capex
regulate their capital Vol-14 dt 2019 and its amendments thereof. The capital investment plan envisaged by as per direction.
expenditure plans 13.03.2023 Nigam is also shared with Genco and Transco in due time in order to create sync
for FY 2023-24 as per between the investments proposed by all utilities. It will also be ensured that
Regulations 9.7 to any additional capital expenditure incurred due to time over-run or unapproved
9.12 of the Haryana schemes, or changes shall not be considered in capital expenditure to be
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
Electricity Regulatory claimed during true-up without any reasonable justification and the same shall
Commission (Terms be subject to approval from the Hon’ble Commission.
and Conditions for
Determination of
Tariff for Generation,
Transmission,
Wheeling, and
Distribution & Retail
Supply under Multi
Year Tariff
Framework)
Regulations, 2019.
12 The Commission Vide memo No. of feeder more than 50% in RDS category and urban feeders more than 25% Partially complied
again directs the no Ch- Sr Circle RDS Urban with
DISCOMs to reduce 33/RA/F- . April to April to April to April Although there is
to
AT&C losses of all 173/Vol-14 no March,2022 march, 2023 March,2022 march, 2023 improvement but
urban feeders below dated Above 50% Above 25% the feeders with
25% and that of Rural 24.04.2023 1 Panchkula 0 0 0 0 higher losses are
feeders below 50% in 2 Ambala 0 1 3 0 still there. More
FY 2022-23 and to 3 Yamunanaga 0 0 0 0 effort required to
submit the Status r make the count Nil.
Report after 2 4 Kurukshetra 0 0 0 0
months of the order. 5 Kaithal 11 6 4 2
6 Karnal 0 0 0 0
7 Panipat 16 4 4 0
8 Sonepat 62 24 10 2
9 Rohtak 42 39 2 0
10 Jhajjar 47 18 1 0

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
UHBVNL 178 92 24 4

13 The Commission Vide memo As per HERC SOP Regulations, 2020 (6.1.e), Discoms have to maintain DT damage Partially Complied
again directs the no Ch-11 F- rate below 6% p.a. in rural areas and 3% p.a. in urban areas. The Financial Year more effort
licensee to bring 173 Vol-14 wise data of DT damage rate is as follows: - required to be put
down the dt. FY DTs damage Rate% Increase/Decrease in in to reduce the
distribution 07.03.2023 Rural Urban Rural Urban transformer
transformer damage 2016-17 11.20 6.31 +1.90 -0.87 damage rate.
rate below the 2017-18 9.84 7.06 -1.36 +0.75
2018-19 10 19 5.64 +0.35 -1.42
prescribed limits in
2019-20 9.60 5.62 -0.59 -0.02
FY 2022-23 and FY 2020-21 9.15 5.09 -0.45 -0.53
2023-24. Any 2021-22 8.69 5.63 -0.46 +0.54
slippage on account 2022-23 (up to 7:16 4.27 -1.53 -1.36
of the timeline shall The following action plan has been circulated in field offices to maintain DT
Jan,23)
lead to penalty as damage rate below 6% in rural & 3% urban areas, during F.Y. 2022-23 & F.Y.
deemed fit and 2023-24: -
appropriate by the xii. Sufficient numbers of LT circuit with separate fuse system will be
Commission as per provided on higher capacity DTs
various provisions of 100 KVA – Up to 2 Circuits
the Act and
200 KVA -Minimum 2 Circuits
Regulations framed
thereunder. Further, 400 KVA – Minimum 3 Circuits
Commission directs 630 KVA – Minimum 4 Circuits
the licensee to xiii. Load on each phase of the Transformer and carrying out the load
provide the action balancing exercise.
plan and the action xiv. Oil level of transformer be checked and be topped up wherever required.
taken to reduce rate xv. Condition of silica gel breather be checked, wherever applicable and
DT damage during FY
necessary action be taken.
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
2022-23 and FY xvi. LT fuse boards be checked and replaced wherever required.
2023-24. xvii. LT rods be checked and replaced wherever required.
xviii. Proper termination with appropriate sizes of Aluminum Thimbles be
done.
xix. Additional Transformer will be provided to give relief to overload
transformer.
xx. Augmentation of transformer will be carried out.
xxi. Conditions of LT cables be checked and worn out cables be replaced
wherever necessary with appropriate size of cable.
xxii. Condition of male & female contacts of GO switches and remedial action
be taken accordingly.
Further, in every WTDs & BODs meeting, monthly damage rate of
Distribution Transformers is reviewed and directions are imparted to field
Vide memo offices for reducing the damage rate, otherwise disciplinary action would be
no Ch- initiated against the delinquent officers/officials.
70/RA/ F-173
Vol-14 The updated data regarding the same will be submitted along with filing of ARR
dt.16.05.202 Petition for FY 2024-25.
3
14 DHBVNL is again Does not relate to UHBVNL Does not relate to
directed to clear the UHBVNL
backlog of defective
metering and to
ensure that at no
point of time the
percentage of
defective meters
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Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
exceeds 2% limit as
per SOP regulations
in vogue
15 The Commission Vide memo The status of single phase and three phase mechanical/electro-mechanical Partially Complied
directs DISCOMs no Ch-11 F- meters as on 28.02.2023, is as under: - with.
especially DHBVNL 173 Vol-14 Sr. Name Number of Progress of Number of As on 28.02.2023,
to replace all dt. No. of Mechanical/ replacement of Mechanical there is no pending
electromechanical 07.03.2023 Circle Electromechanical Mechanical/ /Electromechanica three phase
meters shown meters
Single pending
Three for Electromechanical
Single Three lSingle
meters pending
Three electro-mechanical
pending for replacement at the meters during for replacement as meters left for
1 AMB Phase 10488 phase
719 Phase
10488 phase
719 Phase
0 Phase
0
replacement and end of March 2022 01.04.2022 to on 28.02.2023 replacement.
submit compliance 2 PKL 1524 472 1524 472 0 0 However, 17,191
28.02.2023
report within 3 3 YNR 4522 0 4522 0 0 0 single phase
months from date of 4 KKR 0 0 0 0 0 0 electromechanical
this order. 5 KTL 409 0 409 0 0 0 meters in Sonipat
6 KNL 21 30 21 30 0 0 (14018), Rohtak
7 PNP 1053 0 1053 0 0 0 (1348) and Jhajjar
8 SNP 28784 700 14766 700 1401 0 (1825) reported to
9 RTK 13383 0 12035 0 8
1348 0 be replaced on
1 JJR 5737 0 3912 0 1825 0 priority.
0
Total 65921 1921 48730 1921 17191 0 Sincere efforts
UHBVNL required to zero
It is submitted that there is no pendency left for replacement of three phase
electro-mechanical meters in all OP Circles. The balance single phase meters are down the pendency.
installed in rural areas of Sonipat, Rohtak & Jhajjar Circle which are being
replaced in villages where MGJG work is under progress and not started yet.
However, stiff resistance is being faced in these 'OP' Circles. The progress of
replacement of electro-mechanical meters is regularly reviewed under the
Chairmanship of Worthy Managing Director/Director Operation, UHBVNL. The

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
directions have been imparted to replace the remaining 17191 No. single phase
electro-mechanical meters on priority.

16 DISCOMs are Vide memo The work of smart meter installation has been suspended by EESL from Partially complied
directed to expedite no Ch- 01.02.2023. Notice of Default has been issued to M/s EESL on 01.03.2023 in tune with
the Installation of 25/RA/F- of MoU and contract agreement. Further, EESL has been directed to resume the
Smart Metering 173/ Vol-14 work and services within 15 days.
Project already dated11.04.2 3,91,544 no. of smart meters have been installed (against 5 Lakh) in UHBVNL as
undertaken to 023 on date. As per contract agreement, EESL has to complete the project by Dec
ensure the 2023.
competition of The updated progress report will be shared alongwith the filing of ARR Petition
project within the Vide memo for FY 2024-25.
time lines of no Ch-
agreement executed 70/RA/ F-173
between EESL and Vol-14 dt.
DISCOMs 16.05.2023
17 Further, DISCOMs to Vide memo Keeping in view the challenges faced in EESL project on DBFOOT model, Haryana Not Complied
submit status of no Ch- Discoms are pursuing the matter with MoP to allow the prepaid smart metering Latest status
RFP/NIT along with 25/RA/F- implementation under RDSS on CAPEX/Hybrid financing model to retain the submitted but
their detailed plan 173/ Vol-14 ownership of AMI application as long-term vendor lock-in will create a action still pending.
regarding replacing dt monopolistic situation favoring AMI-SPs who may compromise with meter
of conventional 11.04.2023 quality and ignore Discom/Consumer's genuine concerns. The decision for
energy meters by floating of tenders will be finalized once mode of implementation is decided by
prepaid smart the state government.
meters within two
months of issuance Further, it is submitted that the status of the RFP/NIT for engagement of AMI-SP
of this Tariff Order. Vide memo for implementation of prepaid Smart Metering under UHBVNL remains the same
no Ch- i.e. the mode of implementation of Smart Meter Project is under consideration
70/RA/ F-173 /decision by State Government.
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
Vol-14 dt.
16.05.2023
18 The commission Vide memo iv. Improvement in downloading of meters. Partially complied
directs DISCOMs:- no Ch-20 F- d. There are approx. 31 lac consumers in UHBVNL (Except AP) and out of these
vii. To improve 173 Vol-14 dt meters approx. 80% meters are downloadable and currently the -Showing reduction
efficiency in the 13.03.2023 in provisional billing
downloading percentage is approx. 75% of total consumers or more than
meter reading from 5.42 % in Dec,
activities 90% of the downloadable consumers. The status of meter reading 2021 to 2.97% in
including billing. downloaded is given below (Nov & Dec-22): - Jan, 2023.
viii. To reduce Discom Jan-21 Feb-21 -Licensee further
number of bills Total Downloading % (w.r.t Total Downloa submitted that
rendered on Consumer total meters Consumer ding % continuous efforts
provisional basis. UHBVN (w.r.t are being made to
ix. There should be L total achieve the
no bill rendered meters permissible limit of
on average basis 1392781 36.78 1549652 40.62 provisional billing,
which is 0.1% as per
for more than 2
Disco Nov-22 Dec-22 SoP regulations.
billing cycles
m
failing which Tot Downloa Download Total Downloa Download
consumer shall al ding % ing % Consu ding % ing %
be entitled to UHBV Con (w.r.t (w.r.t mer (w.r.t (w.r.t
claim NL sum total download total download
compensation. er meters able meters able
meters meters
147 74.62 90.88 128692 75.09 90.11
920 4
3

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
e. High billed logic has been modified; hence it will improve the meter reading
and billing performance.
f. MNF (Meter Not Found), ANT (Address Not Traceable) is closely monitored
by concerned SDOs/OP and the progress is monitored on monthly basis by
Director/OP.
v. To reduce number of bills rendered on provisional basis.
c. Current status of provisional billing as well as defective meters for the month
of Dec-22 & Jan-23 is placed at Annexure-A & B respectively.
The progress of provisional billing is as under: -
Status of provisional billing
Sr. No Period % Provisional billing
1 Dec-21 5.42
2 Jan-22 5.04
3 Feb-22 5.61
4 Mar-22 5.02
5 Apr-22 4.67
6 May-22 5.19
7 Jun-22 5.78
8 Jul-22 5.14
9 Aug-22 4.27
10 Sep-22 3.56
11 Oct-22 3.36
12 Nov-22 3.27
13 Dec-22 2.91
14 Jan-23 2.93

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
The above table shows there is continuously improvement in provisional
Vide memo billing cases and NIGAM is trying that no bill will be issued on average
no Ch- basis for more than two billing cycle.
70/RA/ F-173 d. One number JSEs has been deputed at division level to monitor the billing
Vol-14 dt. and consumer complaints on daily basis hence UHBVNL reduced the
16.05.2023 provisional billing to 2.93% Jan-23).

vi. There should be no bill rendered on average basis from more than 2 billing
cycles failing which consumer shall be entitled to claim compensation.
c. Nigam is continuously monitoring the defective meter cases. This results
in timely replacement of defective meters hence this exercise will reduce
the repeated average billing.

d. The status of pending complaints (BR/MCO/PDCO) is reviewed on

monthly basis by Director/OP, this leads to timely resolution of
complaints.
The percentage of provisional billing ending March’23 is 3.32% which was at
5.02% in March’22 and 5.42% in December’21.
Further, it is submitted that efforts are being made by Nigam to reduce the
provisional billing.+
19 It may be noted that Vide memo It is submitted that DHBVNL has already finalized the RFP and got approved from Complied with
in case batteries are no Ch- BODs.
installed by the 59/RA/F- Accordingly, UHBVNL has requested DHBVNL to include 2 no. 5MW Battery
Discoms at their sub- 173/Vol–(14) Energy Storage System (Panipat Jhajjar Circle) in their RFP. The Tendering for
stations and the dated the said works is under process by DHBVNL
same are charged 09.05.2023
during off-peak
hours so that the
stored power can be
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
injected back into
the grid during peak
hours to bridge any
demand-supply gap,
the same shall be
counted towards
fulfilment of storage
RPO.
20 Page 185 Vide memo It is submitted that subsidized tariff for AP category has been retained at par Complied with
The petitioners are no Ch- with previous year's AP tariff.
directed to ensure 48/RA/F- The State Government has released subsidy of Rs. 230 Crore in FY 2022-23 on
that supply of power 173/Vol–(14) account of FSA pertaining to AP consumers. The State Government has provided
to AP / any dated a budget of Rs. 600 Crore on account of FSA pertaining to AP consumers in the
categories of 03.05.2023 FY 2023-24.
consumers, where Further, the sanction orders of Rs. 1592.50 core & Rs. U./5 Crore for release of
the State RE subsidy and Gaushala subsidy respectively for the 1st quarter of FY 2023-24
Government has has been issued by the office of Additional Chief Secretary to Govt. Haryana,
committed a Energy Department
subsidized tariff, is
strictly in accordance
with section 65 of
the electricity act,
2003.
21 Page no 186 Vide memo Vide memo no. Ch-23/RA/F-173/ Vol-14 dated 20.03.2023 Complied with
The Discoms are no. Ch- The Hon’ble Commission Vide Tariff Order dated 15.02.2023 (page no 186) has
directed to file 23/RA/F- directed the Discoms to file revenue realized from MMC for FY 2022-23.
revenue realised 173/ Vol-14 In this regard, the reply in respect of above said directive is as under: -
from MMC in the FY dated (Amount in Rs.)
2022-23 within one 20.03.2023
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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
month from the date MONTH MMC MMC AMT AMT TO CURR CYC REALIZATIO
of this order BILL COVER MMC CHARGES N
COUNT
April 2022 281910 19138198 91374474 20066575 121612494
8 6
May 2022 189582 14032980 70416916 14691433 139200556
6 5
June 2022 188579 14401739 75967690 15159845 149086191
0 4
July 2022 169528 12966708 69171547 14915720 158452208
6 3
August 188549 14143684 78483898 16477006 171860712
2022 8 2
Sep2022 242020 22160997 103817822 25574137 187686874
8 2
Oct 2022 256614 18501632 95629150 21306522 230817040
6 3
Nov 2022 385182 24328685 122442939 29740310 401596391
8 7
Dec 2022 621255 33659205 159526304 45880322 532878535
7 0
Jan 2023 758827 45146573 206168263 56697056 597334405
6 1
Feb2023 788095 41842571 210764197 51866771 607266590
4 1
March 341410 18752204 90383109 23594036 274260864
2023 9 3

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
Total 4411551 27907518 1374146310 33596973 357205286
35 68 0
*since payment is collected against A/c no., therefore it won’t possible to
provide actual realization against Bill ID raised on MMC basis. For preparing
realization data amount of latest payment made by consumer after generation
of MMC Bill is considered.
22 Page no 195 Vide memo The Capex Plan submitted for APR year at the time of filing ARR petition was Complied with
UHBVNL is directed no. Ch- upto Sep. 2022. The works at Sr. No. 7, 9, 10, 11, 12, 14 (2) & 16 were under
to give the 61/RA/F-173 tendering/ approval process. Further these works were carried out in the 2nd
justification of nil Vol-14 half of the FY 2022-23. The detail is as under: -
expenditure against dt. Sr. Description Reply
the approved capex 10.05.2023 No
and to adhere to the 7 Civil allied Works other Rs. 5.31 Cr. has been incurred during FY
Regulation than substation 2022-23
meticulously. buildings
9 Strengthening of 11 kV Rs. 50.50 Cr. has been incurred during FY
lines, 11 kV Ring Main 2022-23
System, New DTs &
normal development
10 Creation of double The works at Sr. No. 10 of the capex Plan
supply source for 33 i.e. "The creation of double supply
kV substations, 33 kV source for 33 kV Sub-stations, 33 kV Ring
Ring Main / Scada MaW SCADA." The creation of double
supply source for 33 kV Sub-stations, 33
kV Ring Main/ Scada was envisaged at
the beginning of the financial year. This
arrangement was to be done to make
sure the availability of uninterrupted

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
power 24x7, due to maintenance work
or outages.
For this arrangement UHBVNL
approached HVPN to get access of bays
at feeding sub-stations of HVPNL. All SE'
s (OP) UHBVNL have also been asked to
identify & supply the data of 33 kV Sub-
stations for the creation of double supply
source.
The above proposal is under process &
likely to be finalized in this financial year.
The reason as explained above lead to nil
expenditure for the said capex works
11 Revamped Work yet to be awarded and NITs are
Distribution under evaluation stage.
Strengthening Scheme
(RDSS)
12 ElectricVehicle Work order of amounting to Rs. 27 Lakhs
Charging was allotted for EV charger at Head
Station Office Building of UHBVNL, Panchkula
and work was completed.
14(2) Commercial Data 1.Invoice not raised by firm.
Migration (IPDS & 2. Migration of Non-R consumers on CC
Balance Areas) &B of all 10 circles has been 100%
completed
16 ERP Implementation Nodal Agency, M/s PFC has been
requested to allow rollout of only one
module of ERP i.e. Project Management

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
under RDSS, however, their response is
still awaited.
23 Page no 201 Vide memo Nigam has submitted the revised Capital Investment Plan for FY 2023-24 as Complied with.
UHBVNL and no Ch- directed in HERC Tariff order dated 15.02.2023 with revised cost of Rs 1000
DHBVNL are directed 51/RA/N/F- crore.
to revise its Capital 168 dated
expenditure plan for 02.03.2023
FY2023-24
accordingly and
submit the scheme
wise details of the
proposed
expenditure to the
Commission within
one month of the
Order.
24 Page no 206 Does not relate to UHBVNL Does not relate to
The Commission UHBVNL
observes that the
low collection
efficiency in five
circles of DHBVNL
reflected under
recovery of revenue
and attributes to
financial losses on
account of additional
borrowings by the

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
licensees to meet
their revenue
shortfall besides
accumulation of
arear which in turn
may convert into bad
debts.
In view of the above,
the Commission
directs DHBVNL to
improve collection
efficiency in above
circles by plugging
loopholes of revenue
leakage.
25 Page no 214 Vide memo The status of pending Non-AP connections is attached as Annexure-I to IV and Partially Complied
DISCOMs are no Ch- summarized as under: - with
therefore directed to 57/RA/F-173 (a) As per SOP Regulations, prescribed timeline is 37 days for LT connection & However there is
make all out efforts Vol-(14) dated 78 days for HT connections improvement
to release all pending 09.05.2023 for both New & EOL.
connections within (b) SOP timelines exclude time taken by applicant in compliance.
the time frame as (c) Average delivery time & % delivery within SOP from 1st January, 2023 to
specified in 31st March 2023 is as under: -
regulations in-vogue. Type LT Supply (up to 50 KW) HT Supply (Above 50 KW)
Average % within SOP Average % within
delivery Time timeline delivery Time SOP
timeline
New 19.34 days 97.18% 57.15 days 83.51 %

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Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
EOL 10.88 days 98.06 % 40.42 days 88.32 %
(d) Pending overdue applications excluding pending on compliance of demand
notice on part of applicant ending 09.05.2023 is as under: -

Type LT Supply (up to 50 KW),

HT Supply (Above 50 KW)
Overdu Load % Overdu Load %
e KW overdu
e KW overdu
e e
New 231 1307.4 2.32%
25 139522 7.79%
.6
EOL 9 219.9 1.10% 21 30392. 6.36%
5
The connections are being released within SOP timelines and there is negligible
pendency of small number of overdue cases, which are due to variety of factors
which are peculiar to each case such as ROW issue, requires augmentation,
delay in self execution, local system constraints, pending on part of
consumer/delay in processing etc. which are resolved and dealt accordingly.
26 Page no 223 Vide memo It is submitted that HERC directive is being complied with and the requisite Complied with
The Discoms and no Ch- information for FY 2022-23 (up to March 2023) has been submitted to HERC and
other obligated 48/RA/F- HAREDA vide letter dated 01.05.2023
entities are directed 173/Vol–(14)
to provide requisite dated
information to the 03.05.2023
State Agency on
monthly basis by
10th of every month
for the previous
month to enable the

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SUPPLY TARIFF FOR THE FY 2024-25

Sr. No. Directives Letter no. and UHBVNL Reply Remarks

date
State Agency to
submit quarterly
report to the
Commission.
27 Page no 229 Vide memo It is submitted that the direction of Hon’ble Commission is being noted for Still some time is
The Commission no. Ch- compliance and the same will be proposed at the time of filing of ARR petition of left for compliance.
directs that in the 46/RA/F- FY 2024-25. Deadline:
next ARR, the 173/ Vol-14 30.11.2023
Discoms will submit a dated
tariff proposal as 01.05.2023
well; it may not
necessarily be for
increase or decrease
in tariff(s) but for
improvement in
tariff design,
reduction in the
number of category
/sub-category, re-
alignment of
demand / fixed
charges etc. The
proposal should
include its impact on
a typical consumer

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