CSPGCL - Cseb.gov.in

PETITION FOR 

PROVISIONAL TRUE UP FOR FY 10-11 

ANNUAL PERFORMANCE REVIEW FY 11-12 

& 

TARIFF RESETTING FOR FY 12-13 

By 

CHHATTISGARH STATE POWER GENERATION COMPANY 

LIMITED

CSPGCL 

Prov. True Up FY 10-11 , APR for FY 11-12, Tariff Resetting FY12-13 

BLANK 

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Contents 

* Abbreviations 

1 Introduction to Chhattisgarh State Power Generation 

Company Limited (CSPGCL) 

2 Background of the Instant Petition 

3 Provisional TRUE UP For FY 2010-11 

4 Technical parameters for FY 2010-11 

5 Annual Performance Review for FY 2011-12 

6 Tariff Resetting Proposal for FY 12-13 

* Tariff Formats 

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Abbreviations 

ACRONYM 

DEFINITION 

A&G Expenses Administrative & General Expenses 

BTG 

Boiler, Turbine and Generator 

BOP 

Balance of Plant 

Control Period Period from FY 2010-11 to FY 2012-13 

CHP 

Coal Handling Plant 

CERC 

Central Electricity Regulatory Commission 

CSERC 

Chhattisgarh State Electricity Regulatory Commission 

CSEB 

Chhattisgarh State Electricity Board 


Chhattisgarh State Power Generation Company Limited 

CSPTCL 

Chhattisgarh State Power Transmission Company Limited 

CSPDCL 

Chhattisgarh State Power Distribution Company Limited 

CSPHCL 

Chhattisgarh State Power Holding Company Limited 

Control Period Period commencing from FY 2010-11 to FY 2013-14 

DPR 

Detailed Project Report 

DSPM TPS 

Dr. Shyama Prasad Mukherjee Thermal Power Station 

EA 2003 Electricity Act 2003 

FSA 

Fuel Supply Agreement 

FY 

Financial Year 

G,T and D 

Generation, Transmission and Distribution 

GCV 

Gross Calorific Value 

GoCG 

Government of Chhattisgarh 

GFA 

Gross Fixed Assets 

Genco 

Generation Company 

HCSD 

High Concentration Slurry Disposal 

HTPS KW 

Hasdeo Thermal Power Station Korba West 

IPPs 

Independent Power Producers 

IDC 

Interest During Construction 

KTPS 

Korba Thermal Power Station Korba East Bank 

MTPA 

Million Tonnes Per Annum 

O&M 

Operations and Maintenance 

PLF 

Plant Load Factor 

PFC 

Power Finance Corporation 

PPA 

Power Purchase Agreement 

R&M Expenses Repair & Maintenance Expenses 

ROE 

Return on equity 

SECL 

South Eastern Coalfields Limited 

SHR 

Station Heat Rate 

Small Hydro Plants Refers to Gangrel, Sikasar and Mini Micro Korba West 

T&D 

Transmission and Distribution 

MYT Regulations Terms and conditions of determination of tariff according to 

2010 

Multi-Year tariff Principles) Regulations, 2010. 

WRD 

Water Resources Department of the Govt. of Chhattisgarh 

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1. Introduction to Chhattisgarh State Power Generation 

Company Limited (CSPGCL) 

CSPGCL was part of the erstwhile Chhattisgarh State Electricity Board (CSEB). 

CSEB functioned as an integrated entity till December 2008 when the State 

Government notified a transfer scheme for unbundling it. The transfer scheme 

resulted in formation of five successor entities for undertaking the functions of the 

erstwhile board. The five entities are:- 

Chhattisgarh State Power Generation Company Limited 

Chhattisgarh State Power Distribution Company Limited (CSPDCL) 

Chhattisgarh State Power Transmission Company Limited (CSPTCL) 

Chhattisgarh State Power Trading Company Limited (Tradeco) and 

Chhattisgarh State Power Holding Company Limited (CSPHCL) 

CSPGCL was entrusted with undertaking the „generation function‟ of CSEB. 

CSPGCL started operations on 1st January 2009. 

Details of Installed capacity for CSPGCL 

NO. NAME OF PLANT COMMISSIONING YEAR CONFIGURATION MW 

Thermal 

1 KTPS KEB 

a TPS PH II 1966-68 4 X 50 200 

b TPS PH III 1976-81 2 X 120 240 

2 HTPS Korba West 

Dr. Shyama Prasad Mukherjee 

1983-86 4 X 210 840 

3 Plant 2007 2 X 250 500 

Total (Thermal) – A 1,780 

Hydro 

1 Hasdeo Bango HEP 1994-95 3 X 40 120 

2 Gangrel HEP 2004 4 X 2.5 10 

3 Sikasar HEP 2006 2 X 3.5 7 

4 Mini Micro H.P.S Korba 2003 2 X 0.85 1.7 

Total (Hydro) – B 139 

Co-Generation 

1 Kawardha Co-generation Plant 2006 1 X 6 6 

Total (Co-Generation) – C 6 

Total Installed Capacity (A+B+C) 1,924.7 

NOTE – The PG test dates of the six units of KTPS Korba East after Life Extension 

and Renovation are: U # 1- 21/12/2004, U# 2- 07/03/2003, U #3- 26/06/2004, U # 4- 

18/12/2003, U # 5- 29/07/2005, U # 6- 22/01/2004. Thus all the six units were 

refurbished in a span of less than two and half years. 

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2. Background of the Instant Petition 

CSPGCL is supplying all its power to CSPDCL at the rate decided by the Hon‟ble 

commission. Hon‟ble commission has fixed the power station wise tariff for the year 

FY 2010-11 to FY 2012-13 vide its order dt. 31.03.11. Instant petition is submitted 

based on the principles laid down in the relevant regulations and Tariff Orders. This 

petition has been divided broadly in three section viz. Provisional True up for FY 

2010-11, Annual Performance Review (APR) for FY 2011-12, and Tariff Resetting 

Proposal for FY 12-13. 

--- 

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3. Provisional TRUE UP For FY 2010-11: 

3.1. As per the tariff philosophy, tariff is worked on the basis of estimated annual 

revenue requirement based on past trend/ normative values with certain 

presumptions; however after preparation of accounts, there is need to realign the 

ARR and the tariff. The exercise of preparation of comparative of the projections 

used in the tariff with the actual values is termed as the „True-up‟. True up is to 

be done based on the audited accounts and actual performance, however as 

finalization of accounts generally takes longer time, instant petition is submitted 

for „Provisional True up‟ for FY 2010-11 on the basis of provisional accounts. 

Petitioner craves leave to submit more accurate data as may become available 

at a later date. Further leave is also craved for additional submission due to 

change in law / court order (including APTEL)/ Govt. notifications as may be 

come to notice on later date. 

3.2. Provisional Accounts duly signed by the head of the finance is enclosed. 

However, due to variance in the principle followed in the preparation of accounts 

& principles followed in the regulations; the values under different account heads 

need to be adjusted and realigned to meet the regulatory requirements. 

On the financial front, the revenue and expense data appearing in the 

Provisional Balance Sheet / Profit & Loss Account of CSPGCL for the period 

under consideration have been relied upon. However, it may be appreciated that 

sometimes the account heads considered in the Balance sheet and those 

defined under the regulatory process do not have one to one co-relation. Such 

situations require proper reclassification, allocation and apportionment of 

expenses. CSPGCL, on its part, submits that such exercise have been 

embedded in the instant petition giving due justification. A brief of various tariff 

components, corresponding accounting heads and adjustments made to meet 

the regulatory prudence is submitted in the table hereunder for kind reference 

please. 

ARR 

Component 

Accounting Head 

in Balance Sheet 

Adjustments 

Considered 

ROE - Calculated as per 

applicable regulation. 

(taxation as per actual) 

Depreciation Depreciation Actual capitalisation 

figures have been 

considered with 

Justification 

Balance sheet/ Profit 

Loss account do not 

provide such data. 

Computed on average 

GFA during the year as 

per method approved by 

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Employee 

Cost 

Repair & 

Maintenance 

Cost 

Employee Cost 

Repair & Maint 

Cost segregated 

from General 

Administration & 

Other Expenses 

A&G segregated from 

General 

Administration & 

Other Expenses 

Interest & Fin. 

Charges 

Working 

capital 

Interest 

(normative) 

Interest & Fin. 

Charges 

adjusted opening GFA 

as per order 

Emp. Cost toward coal 

transportation reduced. 

1.Cost of Lubricant / 

Consumable stores & 

station supplies added. 

2. Water charges 

added 

3. Coal transportation 

Cost & capitalisation 

reduced. 

General Administration 

& Other Expenses – 

Repair & Maint Cost 

(as above) – water 

charges. 

Interest & Fin. Charges 

have been calculated 

as per norms 

- Calculated as per 

applicable regulation. 

Fuel cost Fuel cost Landed cost including 

Costs for EXT CHP / 

CT/BCRW) 

considered. 

Non 

income 

tariff 

Other Income 

No Change 

the commission in last 

tariff order. 

Coal Transportation cost 

is part of fuel cost. 

As per conventional 

accounts cost of 

lubricants, consumable 

stores & station supplies 

water charges are 

booked under Gen. 

Admin. & other 

expenses. However 

under regulatory process 

they are part of Repair & 

Maintenance cost. 

Under regulatory process 

water charges are part of 

Repair & Maintenance 

cost. 

As per regulation, 

Interest & fin. Charges 

have been calculated on 

weighted average rate of 

loan 

As per APTEL order in 

petition no. 137,138,139 

of 2008, utility is entitled 

for working capital 

interest charges 

irrespective whether 

working capital has been 

financed from internally 

or actual loan. 

As per regulation, cost of 

fuel implies landed cost 

of fuel. The methodology 

has been accepted by 

Hon‟ble Commission in 

MYT order. 

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3.3. The opening values for the year get affected only if there is a true up revision for 

the previous year otherwise the closing figures for the previous years as may 

have been approved by the ERC stand valid as opening figure for the year under 

review. Accordingly, the opening GFA, Opening Normative Equity and the 

Opening Normative Loan have been taken from the CSERC MYT order dt 

31.03.2011 and additions during the year have been revisited for the purpose of 

Provisional True up of FY 10-11. Any change in the opening values shall be 

affected only during final true up of 09-10 which shall be taken up after receipt of 

Audited accounts of FY 09-10. CSPGCL adheres to the order without any 

change. 

3.4. Further for additional capitalization, CSPGCL has relied only on the certified 

information regarding completion of capital works in the respective period. The 

reason is that regulatory philosophy calls for capitalization of an asset only at the 

time when it is “Put to use”. As per APTEL order, the cost of asset is considered 

to be the total cost of such asset. To be fair and judicious, CSPGCL on its part 

has not claimed any benefit on any CWIP. 

3.5. In the MYT order, after detail prudence check of data, Commission allowed 

weighted average depreciation for different plants based on the category wise 

asset class employed at respective stations as on 31.03.2010. As no revision of 

accounts has taken place since then, the weighted average depreciation to be 

applied to different plants remains same. The only factor which needs a relook is 

the extent of Additional capitalisation which has actually taken place at the 

various power stations. The same has been taken care of as mentioned above. 

3.6. For calculation of Interest and Finance charges, opening normative loan is as 

per approved closing value for 09-10. As per regulations, repayment has been 

considered equal to depreciation. As far as applicable interest rate is considered, 

it may be appreciated that interest rate during the period under consideration 

have shown distinct upward movement however, as actual computation involve 

some interstate settlement related to MPEB period, in the provisional true up 

weighted average interest rate has been taken as per approved order only and 

no impact of interest rate hike is being claimed at this stage. Leave is craved for 

submission of actual interest rate at the time of final true up. 

3.7. Finally after consolidation of all the above cost components, the summarized 

plant wise actual expenses vis-à-vis the approved ARR is tabulated hereunder:- 

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KTPS, Korba East 

PARTICULARS FY 2010-11 

Amount Rs. in Cr. 

ALLOWED ACTUAL 

Depreciation 30.79 29.11 

Int. on Loan & Fin Charges 14.59 12.52 

Return On Equity 37.60 28.62 

Int. On Working Capital 18.72 20.53 

O&M Expenses 147.09 182.29 

Secondary Fuel Oil Cost 22.00 18.15 

Cont. to P&G Trust 12.35 12.32 

Less - Non Tariff Income 3.85 4.66 

ANNUAL CAPACITY charge 279.29 298.88 

Fuel Charges 231.21 241.01 

ARR 510.50 539.89 

HTPS Korba West 



ALLOWED 

ACTUAL 





O&M Expenses 205.68 207.37 






ARR 872.07 831.07 

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DSPM TPS 



ALLOWED 

ACTUAL 





O&M Expenses 103.39 92.46 


Cont. to P&G Trust (Inclu in O&M) 14.03 14.03 




ARR 828.85 758.69 

HASDEO BANGO HEP 



ALLOWED 

ACTUAL 





O&M Expenses 8.00 10.06 



ARR 27.03 26.80 

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3.8. Reason for variance: 

3.8.1. O&M Cost : 

It includes employee cost, cost of Repair and maintenance and cost on 

administration and general expenses. The actual O&M cost has been taken as 

per the accounts, however the cost incurred on coal transport division / external 

CHP has been reduced from the O&M cost head and added to the Fuel cost 

head. It is in line with the mandate given in regulations and the methodology 

adopted by the Hon‟ble commission at the time of determination of tariff vide 

the detailed MYT order dtd 31.03.2011. 

The variance in O&M is mainly due to following factors:- 

Hon‟ble Commission has allowed R&M for old plants on the basis of previous 

five years of O&M expenses. While submitting the petition, CSPGCL 

projected the O&M expenses as per the CSERC MYT regulation 2010. The 

net expenses for past five years were normalised taking into account an 

escalation factor of 5.17% to bring them at par with FY 2008-09 values. 

However the commission in the MYT order instead of normalisation 

considered the average value of last five years cost. CSPGCL‟s submission 

for normalisation was to bring the net present value of past expenses at par 

with the base year. It may be appreciated that Rs 100/- in 2004-05 cannot be 

equated with Rs 100/ in 2009-10. However simple average as considered in 

the MYT order resulted in lower value for base year consequently O&M costs 

were allowed at lower value. 

It is submitted that water charges for thermal power plant were earlier 

charged by WRD @ Rs. 3.60 per cum. They were increased by almost 100% 

to Rs. 7/- per cum from May 2010, while the format prescribed by the 

Commission for projection of O&M cost from past five year data had no 

component to compensate such abnormal rise in government taxation. For 

example, on five year average basis ( 2004-05 to 2009-10) water charges, 

for KTPS Korba East was less than 5 Cr per year however, the actual for FY 

10-11 has rocketed to Rs. 11.79 Cr for KTPS (about 25% of Repair & 

Maintenance cost for KTPS). Clearly there is a strong case for dealing water 

charges being paid to government as separate component instead of part of 

O&M cost. Interestingly, in all previous orders Commission had allowed water 

tax as a separate component along-with fuel cost. 

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Inflation has also impacted adversely. CSPGCL outsourcers various works 

involving engaging of labour. Minimum labour wages( semi skilled) which 

were Rs. 138.31 per day at the beginning of the year gone up by 14 % 

during the year and became Rs. 158.00. The WPI rose by 6.5% and AICPI for 

Industrial worker rose by 9.5%. This has resulted in increase in cost of 

material, equipment, and works as well as internal employee cost. This has 

also caused increase in the A&G charges. 

As these expenses were unavoidable under the prevailing situations, it is 

requested that the difference being claimed may please be allowed as above. 

Specifically for KTPS, Korba East it is submitted that refurbishment was 

completed in the year 2004. It may be appreciated that refurbished units do 

not require much maintenance in first three years, hence O&M expenses 

remain low in initial years. The tariff was decided on the basis of past 

expenditure. Low expenditure in initial years resulted in lower projections for 

control period, which may be mathematically true but practically infeasible. 

3.8.2. Additional Capitalisation during the year : 

It is submitted that during the year CSPGCL could not get the receivables 

from CSPDCL timely & adequately. There was a cash shortage during the 

year, which hampered the progress of capital works for the running plants. 

Therefore the works have got spilled over to ensuing years. 

3.8.3. Contribution to P&G Trust : 

In the year CSPGCL made contribution towards Pension & Gratuity of Rs. 

77.52 Cr. against the amount allowed in the MYT order of Rs. 53.11 Cr. It is 

to submit that MYT order was issued on dt. 31.03.11. By that time contribution 

had already been made. However in order to honour the provisions of MYT 

order, excess amount paid in the FY 2010-11 is being adjusted in contribution 

towards P&G in FY 2011-12. Accordingly claim for FY 10-11 is restricted to 

ordered value only. 

3.8.4. Secondary Fuel Oil Cost : 

It is to submit that though prices for fuel oil had rising trend but with better 

performance, for all the plants this cost component was kept within limit. 

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3.8.5. Fuel Cost 

In the Korba East higher SHR has mainly resulted in the higher coal 

consumption. Reason for higher SHR is submitted in the Annual Performance 

Report Section. It is requested to allow the SHR and fuel cost incurred in the 

period as per actual only. Beside this, inflationary factors as discussed above 

(in justification for variance in R&M) have also contributed in increase in coal 

transportation cost. 

Marginal increase in fuel cost is observed in DSPM TPS. It is to submit that 

SHR for the plant was better than the approved value. Hence any increase in 

fuel cost is due to uncontrollable factor only and liable to be approved. In fact, 

as per regulation and as per recent APTEL judgement this marginal rise 

should have been a pass through in the billing itself (as is practised by 

Central Generating Stations) instead of adjustment during the instant true up. 

It is only because of direction of Hon‟ble commission vide clause 11.103 

(page 138) of the order, that CSPGCL has waited for this additional claim to 

be raised through instant petition. It is prayed that for future, a pass through 

mechanism as per regulation & the recent APTEL judgement may be allowed. 

CSPGCL also submits that on overall basis the rise in coal cost over the 

ordered value is approximately same as that of rise in actual generation over 

the ordered value, hence deserves pass through on actual basis. 

3.8.6. Statutory Charges: 

Hon‟ble Commission has allowed statutory charges to be passed through 

ARR during MYT period. However during FY 10-11, the actual billing took 

place @Rs 1.44 per unit and the impact of statutory charges was not passed 

to the beneficiary separately. At the time of ARR/ tariff setting, commission 

took this factor into account by providing statutory charges separately (Table 

142, page 133). The statutory charges for FY 10-11 were estimated to be Rs 

76.98 Cr. However, the actual statutory charges applicable for the period 

were Rs 81.47 Cr. Similarly SLDC Charges were accounted separately as 

4.85 Cr for the year. The same has been accounted for in the instant petition 

also. Any revision of SLDC charges (due to true up of SLDC account) may 

please be passed through on actual basis. 

3.8.7. Revenue from sale of power was received @Rs 1.44 per unit. For the plants 

under consideration the revenue from sale of power was slightly higher than 

what was estimated in the tariff order. It may be appreciated that the net sent 

out energy was higher than the order value. 

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3.8.8. The petition filing fee and publication fee is always allowed by CERC. 

Though the same was prayed by CSPGCL yet there was no decision on the 

same in the Tariff order. It is prayed that same may please be allowed at this 

juncture over and above the true up claim tabulated hereunder. 

4. Technical Parameters for FY 10-11 

The following tables provide detail of various performance parameters as 

approved in MYT order and actual parameters achieved in the period FY 2010-11 

4.1. KTPS Korba East – 

The parameter wise analysis is as under :- 

4.1.1. Plant Load Factor & Auxiliary Consumption:- 

In the Tariff order, Commission has placed reliance on PLF and Aux. 

consumption for working out the net generation and subsequently tariff 

computation. The Gross Generation, PLF, Auxiliary consumption and the 

generation are tabulated for the period FY 10-11, are as under :- 

PARAMETERS UNIT Approved Actual 

Gross Generation MU 2925 2939 

PLF % 75.90% 76.26% 

Auxiliary Consumption. MU 308 316 

Auxiliary Consumption % 10.53% 10.76% 

Net Generation MU 2617 2623 

From the above it may be seen that while there is marginal higher Auxiliary 

Consumption, with rigorous pursuance and considerable effort, Gross 

generation has been achieved at 14 MU higher than what was considered in the 

Tariff order, thus the net generation is 6 MU higher. Regarding reasons for 

higher APC, it is submitted that the detailed deliberation made for HTPS holds 

good for KTPS also. It means that at a defined level of fixed cost, the rate per 

unit remains lower than the anticipated. Thus any rise in per unit fixed cost is not 

because of any deterioration in the performance rather it is despite of 

improvement in performance and hence deserves consideration for pass 

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through on „as it is‟ basis. Detail reasoning for increase in fixed cost has been 

given separately in the true up section. 

4.1.2. Specific Fuel Oil Consumption :- 

A significant factor contributing to fixed cost is cost of secondary fuel oil. As rate 

of secondary oil is undisputedly an uncontrollable factor for any generating utility, 

the specific fuel oil consumption assumes significance. It may be seen from the 

table given below that the performance of the station has been better than that 

considered in the tariff order. 


GROSS GENERATION MU 2925 2939 

Total fuel oil cons. KL 6581 5338 

Sp. Fuel Oil cons. ml/kwh 2.25 1.816 

4.1.3. Transit Loss :- 

Transit loss encompasses the loss during transit, handling and storage of coal. 

The performance of KTPS against the allowed level of transit loss is as under:- 


TRANSIT LOSS % 1.25 1.21 

4.1.4. Station Heat rate :- 

It is the heat consumed for generation of one unit of electricity. The KTPS 

performance is given hereunder: - 

PARAMETER UNIT Approved Actual 

Station Heat Rate Kcal/ kwh 2975 3187 

It appears from the above, that there is considerable higher heat consumption 

than what was anticipated in the order. However, the heat rate achieved is not in 

any sudden deviation from the historical trend. The heat rate for FY 10-11, 

matches with the heat rate for 09-10. In FY 09-10 it was 3158 kcal/kwh and the 

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same trend continues in the current year. It only shows that the higher heat rate 

is not a result of any specific O&M fault, as any such operational error cannot 

span over three consecutive years. As far as quality of O&M practices is 

concerned, it is submitted that CSPGCL has same set of policies and technical 

expertise at all the plants. At HTPS and DSPM TPS the CSPGCL is running the 

stations within the benchmarks, hence it does not appeal that the same utility 

can be flawed for not having proper O&M practices. This leaves the issue of 

feasibility and adequacy of the benchmark norm. Unlike HTPS and DSPM TPS 

where the norms fixed by central Commission (which in turn, were based on 

thorough study of many plants, undertaken by CEA) provided a basis for fixing 

technically justifiable norms, unfortunately, for KTPS no such data was relied 

and considered. CSPGCL has raised this issue consistently but unfortunately 

the issue could not be redressed. CSPGCL submits that the benchmark 

considered in the tariff order was unrealistic and as such cannot be considered 

as sacrosanct during the prudence check of actual parameters achieved. The 

facts in support of the argument are:- 

‣ When no independent expert body data is available for such smaller size 

units, an environment scan should have been undertaken to test the 

feasibility. CSPGCL has relied on the Review of Thermal Power Stations 

published by CEA. The data related to such power stations indicate that 

almost all such stations are running with more than 20% variation from the 

design heat rate. The table given below shows the details:- 

Power Station Unit Size Capacity 

Design 

SHR 

FY 

2009-10 

Deviation 

from 

SHR 

FARIDABAD 2X55 110 2798.3 4610 64.74% 

PARAS 1X55 55 2686 3900 45.19% 

NEYVELI TPS -I 6X50+3X100 600 2739.3 3932 43.54% 

RAJGHAT 2X67.5 135 2580.3 3696 43.24% 

ENNORE TPS 2X60+3X110 450 2587.4 3369 30.21% 

DHUVARAN 2x110 220 2417.0 3053 26.31% 

CHANDRAPURA(JHAR.) 3X130+3X120 750 2350.5 2935 24.87% 

In view of the above, the SHR allowed in the order needs to be reviewed. 

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‣ Another aspect of environment scan is to refer to the orders of different 

Commissions for similarly placed sets. A Table of various orders is given 

below : 

Unit rating 

Approved 

Heat rate 

Particulars 

in MW 

Period (kcal/kwh) 

1 ENNORE TPS 2x60+3x110 FY 10-11 3200 

2 PANIPAT TPS-1 to 4 3x110+1x117.8 FY 11-12 3050 

3 NEW COSSIPORE TPS 2X50 FY 08-09 TO 10-11 5125 

4 SIKKA TPS 2X120 FY 08-09 TO 10-12 3100 

Further, the Section 61 of Electricity Act says that in case of generation norms 

SERCs shall be guided by the decisions of CERC. For such smaller sized 

units CERC has allowed SHR as under :- 

Particulars 

Unit rating 

in MW Period 

Approved Heat 

rate (kcal/kwh) 

1 NLC TPS-I 6x50+3x100 FY 09-14 4000 

2 Chandrapura TPS 3x130+3x120 FY 09-14 3100 

Importantly all theses plants are getting better quality of coal than KTPS. 

‣ Logically too, it may be seen that for new power stations of 210/250 MW 

capacity (with reheat and regeneration), the central Commission has fixed 

the benchmark of 2500 Kcal/ Kwh giving a margin of about 10% over the 

design heat rate. It needs to be appreciated that 40 year old units will have 

much higher deviations. A table of such deviations prescribed by various 

standards is given hereunder for ready reference please. 

o 

o 

o 

o 

o 

DIN 1943 : increase in heat rate of 0.7% every year with age 

IEC – 60953 -2 : increase in heat rate of 0.6% every year with age 

BHEL PG test procedure : increase in heat rate of 0.6% every year with age 

ASME PTC – 6 R (1985) : increase in heat rate of 0.4% every year with age 

Report of the Expert Group constituted by CERC to review the operational 

norms for thermal power stations: 0.4% per year as per ASME PTC-6R. 

(Reference : MERC‟s order on petition no.115 of 2008) 

‣ Other wise also it does not meet logic that just due to renovation any set can 

ever achieve the same status as a new set can be expected to perform. It 

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can be seen from performance over last six years (since renovation) that 

much more benefits have been already derived from these units than the 

cost of renovation incurred. The design heat rate for station was theoretically 

2557 kcal/kwh after renovation. For 40 year old units, deviation of only 20- 

25% needs appreciation rather than ridicule. Perhaps it may be useful to 

note that pre renovation, the approved design heat rate for 50 MW sets was 

itself 3270 Kcal/ Kwh and even with just 10% deviation it would have 

achieved SHR of 3600 Kcal/ KWh. 

‣ The Korba East units are vintage design. As per basic design itself, these 

units have lower thermal efficiencies than what is applicable for KWU design 

sets commissioned in the late eighties/ nineties. The fifty Megawatt sets 

even do not have reheat cycle which is a very crucial design factor for 

thermal efficiency of a plant. In Renovation too, it is not possible to convert a 

non reheat unit to a reheat unit. It may be useful to note that as per 

Electricity Act 2003, the word „Authority‟ is used only for Central Electricity 

Authority. The Act stipulates that on technical matters, CEA holds the final 

word. In December 2009, CEA has issued a National Perspective Plan for 

Renovation, Modernisation And Life Extension of Thermal Power Stations for 

the period up to 2016-17. The plan accepts that units of less than 100 MW 

do not hold significant scope for improvisation in efficiency through 

renovation. This fact also needs to be considered while deciding achievable 

SHR target for KTPS. 

In view of the above, it is submitted that the target set by Commission in the 

order are impossible to achieve. Such impossibility, if not corrected during the 

true up then it will not only lead to an impossible situation for the utility but will be 

in contradiction of the National tariff policy too. 

CSPGCL understands that generally there is reluctance to revisit the 

performance parameters, however, the instant case is a fit case for review in 

accordance to law also. Here, kind reference is invited to the cardinal principle of 

law, the body of civil law (Corpus Juris Civilis) relies on the Latin maxim that 

„Impossibilium nulla obligatio est‟ i.e Nobody has any obligation to the 

impossible. Any law or statue cannot convert an impossibility into possibility and 

no one should be forced to be liable to pay for not achieving that impossibility. 

Otherwise also, National Tariff Policy and various decisions of APTEL have 

repeatedly emphasized the need for fixation of tariff on achievable targets only. 

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If a utility suffers from cash starvation due to unrealistic presumptions in tariff 

fixation, it cannot be in consumers‟ interest too. CSPGCL prays for re-fixation of 

normative SHR at 3200 Kcal/Kwh. 

It is also submitted that though Korba East Plant has been continuously one 

of the top performing plant in its category (50/120 MW in State/Govt.sector as 

per CEA‟s yearly report on Review of Performance of Thermal Power Stations) 

for last so many years, yet year by year it suffered because of allowing lower 

SHR in Tariff than what could be achieved. CSPGCL humbly submits that 

commercially it does not make any sense to generate power from a plant 

which even after achieving high status in its category is unable to realize 

even the variable cost of generation. While the alternate source of power 

costs more than Rs 3.10 /unit, the cost of marginal power from KTPS is 

less just about 92 paise /unit (at actual SHR), any disallowance of fuel cost 

will not only be heartbreaking but commercially & legally untenable too. 

Last but not the least, CSPGCL humbly submits that it has no qualms in 

making further effort to improvise and strive for better performance, however 

feasibility must be considered.. CSPGCL also submits that it is ready to engage 

any third party such as CEA/ CPRI, if Hon‟ble commission consider appropriate 

to ascertain reasonable range of SHR for such sets, so that the issue can be 

settled for once and all. However, it is prayed that till such time, such an 

exercise is taken; the actual cost of fuel must be allowed. 

4.2. HTPS Korba West – 

The parameter wise analysis is as under :- 


In the Tariff order, Commission has placed reliance on PLF and Aux. 

consumption for working out the net generation and subsequently tariff 

computation. The Gross Generation, PLF, Auxiliary consumption and the 

generation are tabulated for the period FY 10-11, are as under :- 

PARAMETERS UNIT Approved 

FY 10-11 

Page 20 

Actual 

GROSS GENERATION MU 6685 6696.3 

PLF 90.85% 91.00% 

AUXILIARY CONS. MU 582 641.6 

Aux Cons 8.70% 9.58% 

NET GENERATION MU 6103 6054.7



From the above it may be seen that while there is higher gross generation, the 

net generation is lower than the expected. The reason is higher auxiliary 

consumption. It is essential to recall that as per the regulation, the allowed 

auxiliary consumption as per the regulation was 9% and not 8.7%. The order 

states that Commission has considered this optimization based on the actual 

auxiliary consumption for FY 10-11 as prevailing on 16 th March. Humbly, 

CSPGCL prays to differ. It is submitted that the assumption of 8.7% auxiliary 

consumption at HTPS Korba West was incorrect information. In fact neither in 

the petition nor in TVS any such figure was confirmed by the petitioner. In fact, 

at that time, there were two different formulas for calculation of auxiliary 

consumption. Since inception of the plant, as per prevailing practice throughout 

India (computation accepted by CEA also), the Percentage Auxiliary 

consumption used to be computed as :- 

Consumption recorded by UAT + Consumption recorded by Station Xmer x100 

Gross generation recorded at Generator Terminals 

This formula got changed with the new regulation in January 2010. Now it is = 

Gen. recorded at Gen. Terminals - Sent out energy recorded at HT side of GT x100 

Gross generation recorded at Generator Terminals 

It may be seen that with the above change, two new components got added to 

the Auxiliary Consumption which was computed with the previous formula. One 

is the Transformer losses (GT, UAT & Reserve transformer as sent out energy 

now being recorded at HT side instead of earlier reading at LT side) and the 

other is Generator Static Excitation system load. Theses transformation losses 

were earlier computed as part of Transmission losses and now the same has got 

transferred to Auxiliary consumption. As total losses remain same, to make a 

true comparison with the benchmarks, the benchmarks need to be realigned by 

increasing the allowed Aux. consumption and at the same time compensating it 

from the transmission losses. The transformation loss at GT at 210 MW load is 

estimated (as per GTP) to be 746 KW. Thus the loss is 0.35%. Similarly the 

actual measured excitation loads 854 KW (actually measured on 01.12.2011). 

Thus the excitation load contributes another 0.41% of load. Further, the loss at 

station and UAT (put together) is estimated to be approximately 0.15% of the 

unit load. At full load, all the three factors put together comes out to 0.91 %. For 

Page 21



excitation system load, it may be noted that in the CERC MYT regulation 2009 

(adopted by CSERC also), a clear demarcation has been made for hydro plants 

having rotating excitation system and static excitation system. However, this 

differentiation could not be included in the chapter on thermal plants probably 

due to the fact that since last many years the new sets of 200/210/250 MW 

series are coming with rotating excitation system only. DSPM TPS of CSPGCL 

is also fitted with rotating excitation system. Therefore, thermal plants with static 

excitation system need to be provided additional allowance for auxiliary 

consumption. Further it may be seen from the formulae which was used 

previously that as per old computation method the type of excitation system had 

no impact on the auxiliary consumption computed. 

In view of the above it may be appreciated that the 8.7% auxiliary consumption 

computed as per the previous formulae stands equivalent to 9.6% auxiliary 

consumption as per the formulae now being used. Earlier this difference was 

accounted in the energy balance in the transmission loss and now the same is 

booked as auxiliary consumption thus there is no change in the overall energy 

balance. 

In view of the above, it is prayed that the auxiliary consumption of 9% allowed 

in the regulation on the basis of 5 year historic data needs to be revisited and 

modified to 9.9% and actual auxiliary consumption of 9.58% for FY 10-11 may 

be accepted on as it is basis. Similarly 11% aux. consumption shall be allowed 

for KTPS, Lower compensation is claimed due to rotary excitation on unit no 6. 


It may be appreciated that specific fuel oil consumption achieved in HTPS is 

almost 50% lower than the national norm of 1 ml/kwh for the new sets. CSPGCL 

wish to submit that while assessing the performance of the utility, its contribution 

to the national exchequer by saving precious forex may also be kept in view. 



TOTAL FUEL OIL CONS. KL 6685 2793 

SP. FUEL OIL CONS. ml/kwh 1 0.417 

Page 22




Transit loss encompasses the loss during transit & handling and storage of 

coal. Performance of HTPS against the allowed level of transit loss is as 

under:- 




The HTPS performance is given hereunder: - 



It may be appreciated that with concerted & focused efforts in the FY 2010-11 

the HTPS performance was one of the best in previous years. However with the 

aging units (the last unit will be completing its life this year) though it may be 

extremely difficult to consistently repeat such performance yet CSPGCL will do 

its best to perform within the permissible range. 

4.3. DSPM TPS Korba – 

The parameter wise analysis is as follows :- 


The Gross Generation, PLF, Auxiliary consumption and the generation are 

tabulated for the period FY 10-11, are as under :- 



PLF 96.06% 96.81% 

AUXILIARY CONS. MU 321 331 

Aux Cons 7.64% 7.81% 

NET GENERATION MU 3887 3909 

Page 23



From the above it may be seen that on all the parameters the performance has 

been above par except auxiliary consumption which is marginally higher. It is 

essential to recall that as per the regulation, the allowed auxiliary consumption 

was 9% and not 7.64%. The order states that Commission has considered this 

optimization based on the actual auxiliary consumption for FY 10-11 as 

prevailing on 16 th March., CSPGCL humbly prays that the assumption of 7.64% 

auxiliary consumption at DSPM TPS was not based on correct information. It is 

submitted that as auxiliary consumption achieved by CSPGCL was well within 

the value allowed in regulation hence the same is liable for approval. 


It may be appreciated that specific fuel oil consumption achieved in DSPM is 

more than 50% lower than the norm. CSPGCL wish to submit that while 

assessing the performance of the utility, its contribution to the national 

exchequer by saving precious forex may also be kept in view. 



TOTAL FUEL OIL CONS. KL 4208 1323 

SP. FUEL OIL CONS. ml/kwh 1 0.312 


Transit loss encompasses the loss during transit, handling and storage of coal. 

The performance of HTPS against the allowed level of transit loss is as under:- 




The DSPM performance is given hereunder: - 



Page 24



From the above it may be seen that DSPM TPS for the continuously second 

year has outperformed the bench mark levels in the regulations. It is also 

noteworthy that DSPM TPS is governed by the norms prevailing at national 

level. 

4.4. HASDEO BANGO HEP – 

The parameter wise analysis is as under:- 

S. 

Approv. Actual 

PARAMETERS UNIT 

No. 

10-11 2010-11 

1 GROSS GENERATION MU 125.65 125.99 

2 AUXILIARY CONS. MU 1.5839 1.5770 

3 NET GENERATION MU 124.07 124.41 

It may be appreciated that on all parameters, performance is above par. 

4.5. Small Hydro & Cogen Plant – 

It is submitted that regarding Cogen plant ,CSPGCL did not make any plant 

specific submission in the last MYT tariff petition. The only prayer was the 

generic tariff awarded by the commission to all the other biomass plants in the 

state shall be allowed to Cogen Kawardha plant also. It is well settled position 

that true up is taken only in such cases where the tariff is plant specific. In case 

of generic tariff, neither the true up nor the APR is applicable. As far as tariff 

resetting is concerned, CSPGCL sticks to its earlier proposition that the 

Kawardha Cogen tariff shall continue to be governed by the generic tariff as may 

be applicable for the other bio mass plants in the state and all revisions / 

amendments in the applicable orders may be passed on to this plant also. 

Regarding small hydro plants it is submitted that the tariff has been computed in 

the order (in accordance to regulation too) on the basis of 2008 regulation for 

Renewable sources of energy. The said regulation does not have any clause 

related to true up. Further when the detail order was issued on 30.04.11, 

CSPGCL made humble request that the order do not contain plant specific data 

for such renewable energy plants and in absence of segregation of data it may 

not be possible to make any plant-wise comparison. However Hon‟ble 

commission deemed it fit not to react. Accordingly the only possible comparison 

is that on aggregate basis operational performance may be reviewed. On 

Page 25



aggregate basis against the total gross generation target of 55.78 MU from all 

the renewable energy sources the actual achievement has been 55.88 MU and 

against sent out energy estimation of 52.78 MU, 52.75 MU were sent out during 

the year. Looking to the above no specific request is preferred at this point of 

time for true up for such renewable energy sources taken on aggregate basis. 

4.6. Summary indicating impact on variable /fixed charges for different 

plants & overall surplus / deficit for CSPGCL for FY 2010-11: 

Finally the intent & purpose of the whole true up exercise is to arrive at the 

net surplus / deficit incurred by the utility with respect to the norms of 

operation set for the utility during the year. As per regulation the gains are to 

be shared between the utility the beneficiary & the tariff stabilization fund . 

From the performance data it may be appreciated that CSPGCL has overall 

performed better than the norms set in the tariff order. To work out the 

quantum of such gains CSPGCL has adopted a simplistic model. 

In the model for energy charges calculations have been made 

considering the normative SHR, Sp. fuel Oil consumption, transit loss & 

auxiliary consumption. However in light of the detailed reasoning given in the 

chapter related to operational parameters achieved in FY 2010-11, CSPGCL 

expects that Hon‟ble commission will allow the SHR for Korba East and 

Auxiliary consumption for Korba West plant to actual levels. The same has 

been accounted for in the model. Further as unit rate of coal & GCV of coal 

are established uncontrollable factors they have been considered at actual 

level. With these factors the fuel cost in respect of actual sent out energy has 

been worked out and it has been compared with the actual fuel cost incurred 

by the utility. In short the actual cost has been compared with the theoretical 

cost which would have occurred if all the plants would have performed 

exactly in accordance to operational parameters assigned to those plants. 

Page 26



The surplus of theoretical cost over the actual cost is the net gain achieved 

through improvement in performance parameters. 

Impact on Energy Charges :- 

HTPS KTPS DSPM 

Normative SHR (Kcal/ Kwh) 2650 3187 2500 

Normative Oil Consumption (ml/ Kwh) 1 2.25 1 

GCV of Oil (Kcal/ Kl) 10000 10000 10000 

Actual GCV of Coal 3534 3306 3444 

Sp. Coal consumption on actual GCV & 

Normative SHR(Kg/ Kwh) 0.747 0.957 0.723 

Normative transit loss 0.30% 1.25% 0.80% 

Rate of Coal with actual transit loss 877.82 855.45 956.99 

Rate of coal with Norm. transit loss 877.84 855.75 957.16 

Actual Gen (MU) 6696.30 2939.45 4240.07 

Coal Cons (MMT) adjusted for Actual CV, 

Actual Gen. and applicable normative 

parameters 

5.002 2.813 3.066 

Normative Cost of Coal Consumed (Cr Rs) 439.12 240.76 293.42 

Actual Cost incurred 419.77 241.01 288.24 

Savings due to performance improvement 19.35 -0.24 5.09 

Total Impact Savings/Excess Expenditure 24.20 

Based on the same lines the gain through better performance has been 

derived in respect of fixed cost also. For such derivation the fixed cost per 

unit allowed in the order has been multiplied with the actual generation. 

Fixed Cost Allowed 

Sent Out Considered in Order 

Per unit Fixed cost as per 

order 

Actual Sent out Unit 

Fixed cost applicable as per 

order 

Actual Fixed Cost incurred 

Savings/ Excess 

Total Impact on Fixed Cost 

HTPS KTPS 

DSPM 

TPS Bango 

446.87 279.29 539.11 27.03 

6103 2617 3887 124.07 

0.732 1.067 1.387 2.179 

6054.67 2623.16 3909.12 124.41 

443.30 279.95 542.25 27.10 

411.30 298.88 470.45 26.80 

32.00 -18.94 71.79 0.31 

85.17 

Page 27



Out of the total gains due to performance improvement, as per Clause 5.6 to 5.9 of 

the MYT regulation, it is proposed that the 1/3 rd of the gains may be passed to the 

beneficiary, 1/3 rd may be reserved for crediting to the tariff stabilisation fund and 1/3 rd 

shall be allowed to be retained by the generating company as incentive. Accordingly 

the summary of surplus / deficit resulting in claim / recovery is tabulated as under. 

KTPS HTPS DSPM Bango 

Approved ARR 511 872.1 829 27.03 

Estimated Revenue 377 878.8 560 17.87 

Deficit / Surplus -134 7 -269 -9 

Total Statutory Charges Estimated in 

Tariff order 

76.98 

SLDC Charges (Total) 4.85 

Total Deficit/ Surplus 

anticipated for 4 plants -487.01 

Actual ARR 539.89 831.07 758.69 26.80 

Revenue Received 377.735 871.872 562.914 17.915 

Actual Deficit / Surplus -162 41 -196 -9 

Total Actual Statutory Charges 

applicable 

81.47 

Incentive Claimed 36.45 

SLDC Charges (Total) 4.85 

Actual Total Deficit/ Surplus 

anticipated for 4 plants -448.79 

Surplus/ Deficit Claim 38.22 

It is submitted that at present CSPGCL has huge outstanding receivables against 

CSPDCL (to the tune of 700 Cr.) The impact of provisional true up of FY 10-11 may 

be set off against outstanding receivables prevailing at the time of order. 

--- 

Page 28



5. ANNUAL PERFORMANCE REVIEW FOR FY 2011-12 

The performances as well as financial parameters have been covered in detail in 

the preceding section. Further the abridged projections of financial parameters 

have been detailed in the detailed formats for tariff resetting. Hence same are 

not being repeated. The discussion in this section is limited to actual 

performance parameters for 11-12. 

Actual performance of power house for the period APR‟11 TO SEP‟11 and 

projections for FY 2011-12 are as tabulated below: 

S. 

No. 

PARAMETERS 

KTPS, Korba East 

UNIT 

Approv. 

11-12 

Actual for 

APR'11 to 

SEP'11 

Projection 

for 

FY 11-12 

1 GROSS GENERATION MU 3024 1440 2937 

2 AUXILIARY CONS. MU 313 159 323 

3 NET GENERATION MU 2711 1281 2614 

4 Sp. Fuel Oil cons. ml/kwh 2.150 2.066 2 

5 SHR Kcal/kwh 2950 3143 3200 

6 TRANSIT LOSS % 1.20 1.194% 1.2 

DSPM TPS,Korba 

S. 

No. 

PARAMETERS 

UNIT 

Approv. 

11-12 

Actual for 

APR'11 to 

SEP'11 

Projection 

for 

FY 11-12 

1 GROSS GENERATION MU 3733 1246 2943 


3 NET GENERATION MU 3397 1141 2678 


5 SHR Kcal/kwh 2500.0 2543 2500 

6 TRANSIT LOSS % 0.75 -- 0.8 

Page 29



S. 

No. 

PARAMETERS 

HTPS,Korba West 

UNIT 

Approv. 

11-12 

Actual for 

APR'11 to 

SEP'11 

1 GROSS GENERATION MU 6050 3205 

Projection 

for 

FY 11-12 

6050 


3 NET GENERATION MU 5506 2881 

5451 


5 SHR Kcal/kwh 2650 2582 2650 

6 TRANSIT LOSS % 0.300 -- 

0.3 

S. 

No. 

1 

2 

4 

PARAMETERS 

HBHPS , MACHDOLI 

UNIT 

Approv. 

11-12 

Actual for 

APR'11 to 

SEP'11 

GROSS 

GENERATION MU 274 162.283 

AUXILIARY 

CONS. MU 2.74 0.812 

NET 

GENERATION MU 271.26 161.47 

Projection 

for 

FY 11-12 

260 

2.60 

257.40 

In the above context, CSPGCL submits :- 

Aux. Consumption at HTPS/ KTPS : it is submitted that for deviation in Aux. 

consumption at KTPS as well as HTPS the submission made in the true up 

section continues. 

SHR of KTPS: Detailed deliberation has been submitted in true up section. 

PLF for KTPS :- Nothing was submitted in the true up section due to the fact that 

Hon‟ble Commission has itself considered the issue at the time of fixation of 

target PLF for 10-11. The Commission considered PLF for KTPS at 75.90% for 

10-11 in the tariff order, however, the same has been considered at 78.25% and 

78.50% for FY 11-12 and FY 12-13 respectively. CSPGCL requests for review of 

these targets as the same are unachievable for the 40 year old sets. The inferior 

coal quality over a long span of time has also contributed to significant wear and 

tear of the plant which has hampered its capacity in an adverse manner. It is 

submitted that the target set by Commission in the order are impossible to 

Page 30



achieve. Such impossibility deserves correction by the Hon‟ble Commission as 

has been amply demonstrated during the PLF target setting last year. CSPGCL 

on its part is ready to submit that efforts are on to improvise and achieve higher 

generation than what was considered for FY 10-11. It is to submit that both the 

units 120 MW are having high eccentricity & high vibration resulting in load 

restriction to around 90-105 MW. Accordingly it is prayed that in most optimistic 

scenario, normative PLF for KTPS may be targeted to 76% only, beyond which 

anything may force a compromise on safety aspect of the plant. It is also 

submitted that even 76% is still, a shade higher than 75.90% considered in the 

previous order. 

PLF of DSPM TPS during the Current Year: DSPM TPS was commissioned 

in 2008-09, since than the units are performing at higher PLF than the prevailing 

norms all over India. In 09-10 as well as 10-11 units have out performed the 

prevailing norms of 80% & 85 % by substantial margin. Further it is matter of 

record that not a single paisa incentive for this outstanding performance in FY 

2009-10 was allowed by the Hon‟ble commission and for 10-11 the Hon‟ble 

commission decided to upgrade the norm of PLF from 85% to 96.06% which is 

to the faith and knowledge of CSPGCL is the highest PLF criteria decided by 

any commission for any plant at any time in the history of the regulatory regime. 

This has deprived CSPGCL from its fair share of incentives realizable as part of 

the proceeds of sale of excess generation. 

However, in 2010-11 due to the turn of destiny the DSPM TPS has suffered from 

a rare unfortunate coincidence of back to back accidents in both units. 

The unit no. one during overhaul was detected with minor cracks in one of the 

LP turbine blade. Immediately the same were taken for thorough inspection by 

the BHEL (OEM) experts and subsequently few more blades were detected to 

be suffering from same phenomenon. It necessitated change of the complete set 

of blades by new ones. Even with the best efforts, to procure blades the nonavailability 

of blades at BHEL as well as all power stations having similar units, 

forced outage of the set for 48 days. This incident took place while box up of the 

turbine module was in progress and contract for overhaul was with BHEL only. 

This negates any possibility of any cracks due to sudden jerk because of maloperation. 

It may be useful to note that before the overhaul there was no 

abnormal vibration in the unit. This also proves that crack was not due to any 

malpractice and deserves to be treated as „force majeure’ condition. 

Page 31



In the second accident, unit no. 2 generator transformer caught fire. Within 

minutes the inferno resulted in total loss of the generator transformer. The bus 

duct melted down to pieces. Fortunately there was no casualty. All efforts were 

made to arrange another generator transformer of the similar specifications but 

even in the plants where generator transformer for 250 MW sets were available 

(JSPL Raigarh & STPS Sarni). The HT side of GT was designed for 400 kV 

evacuation while at DSPM power evacuation is at 220 kV. The best supply 

schedule of BHEL indicates that the new Generator Transformer may be 

available at the earliest in the April 2012. Keeping the set down 9 months would 

have resulted in severe loss of generation resulting in very high cost of power 

purchase for the sole beneficiary CSPDCL and resultantly for the consumers of 

the state. It is worthwhile to mention while the cost of generation at DSPM TPS 

is Rs. 2.31/kwh only the alternate cost of power for CSPDCL through short term 

power purchase in the FY 2011-12 has been allowed at Rs. 3.10/kwh (table 210 

page 194 of MYT order Dt. 31.03.11) Considering this all possible alternatives 

were explored thoroughly and in a very calculated way it was decided to put in 

service a retired generator transformer of HTPS Korba West as stopgap 

arrangement. However as this generator transformer was designed for 210 MW 

set and primary side voltage differs from the generating voltage of the DSPM 

unit the arrangement is not free from constraints. Further, the GT has already 

served more than 20 years and was detected with some abnormality before 

replacement at Korba West. All these technical limitations require the generation 

from the set to be restricted to 200 MW. Thus the unit even after becoming 

operational is capped to maximum 200 MW installed capacity status. 

From the chain of events as narrated above (documentary evidence if 

required shall be provided by CSPGCL at the time of TVS) makes it explicit that 

occurrences fit to be considered as a „force majeure’ condition. 

These two accidents caused outage of units for about 158 days (including AOH 

of each units) and resultantly during the first six months of FY 2011-12 the PLF 

achieved was only 57% and for the next six months also the maximum capacity 

for the plant suffers from a capping of 450 MW instead of 500 MW. Even if it is 

presumed that for the five months (Nov-Mar) the plant performs at 85% of 

available 450 MW capacity then the overall generation at the end of year on 500 

MW capacity rating may be maximum 67%. CSPGCL prays that performance of 

DSPM TPS in current year may be reviewed in light of the handicapped cause 

due to force majeure conditions. 

Page 32



Further, it is submitted that for FY 2012-13 the target generation may please be 

revised to 85% PLF for 450 MW capacity in the first quarter (replacement of new 

GT is expected by June 2011 and than 500 MW capacity for the remaining 3 

quarters which come out to 82.88% on aggregate basis. 

Performance of HEP Bango during the Current Year: - The HEP Bango is 

expected to generate approximately 100% more energy than last year. With 

higher rainfall, it is expected to achieve about 260 MU generation. However it 

may still not be able to achieve full design potential of 274 MU, because due to 

lower rainfall in 10-11 the opening dam level for 11-12 was much lower than 

normal and in the initial period of rains the last year deficit was marked up. In 

Hydel stations typically a poor rainfall effects performance of two financial years 

as the rain cycle is different from the financial year cycle. However, if rains in FY 

12-13 continue to be same as that of FY 11-12, it is expected that full design 

energy of 274 MU may be generated from the plant. 

--- 

Page 33



6. TARIFF RESETTING FOR FY 12-13 

For tariff resetting, detail calculations are submitted in the prescribed formats. For 

resetting following is requested. 

6.1. TREATMENT OF WATER TAX FOR TPS: In the MYT order, the O&M cost 

projections were worked out inclusive of water tax on the basis of five year historic 

data. As water tax is govt. levy and as detailed in pre-paras the water tax / 

charges since then has more than doubled and as per notification the yearly 

increase is 15%. It is submitted the methodology needs an urgent review. For 

KTPS / HTPS it has created very difficult situation for the two plants. It is 

submitted that for KTPS the component of water tax in the average worked out 

from five year data was less than 6 crs. While the actual tax was more than 11 crs 

in FY 2010-11 and the same will be even higher in current year due to 15% yearly 

increase for the same quantity of water. It may be appreciated that the Repair & 

maintenance cost for KTPS has been allowed in the order at Rs. 50 crs. for FY 11- 

12 and if more than 13 cr. is paid as water tax then the R&M becomes clear 

casualty. It is prayed that for the thermal power plants water tax paid to the Govt. 

should not be treated as R&M cost of the plant and shall be pass through. R&M 

cost approved in the order may be allowed exclusive of water tax considering the 

impact of inflation for FY 2011-12 & FY 2012-13. 

6.2. RESETTING OF PERFORMANCE TARGETS FOR HTPS / KTPS 

Due to the reasons stated in pre-paras following parameters need a review 

during the tariff resetting:- 

S.N. Parameter Justification 

Auxiliary Consumption The submission on this issue is the same as 

1 

for HTPS / KTPS detailed in the True up section. 

2. 

3 

SHR / PLF for KTPS 

Korba East 

PLF for KTPS Korba 

East & DSPM TPS 

The submission on this issue is the same as 

detailed in the True up section. 

The submission on this issue is the same as 

detailed in the APR section. 

It is prayed that above may be allowed for FY 12-13. Further statutory charges may 

be allowed to be recovered on actual basis and SLDC and such other miscellaneous 

charges may be allowed on aggregate bill as has been allowed in last order. 

For Kawardha Cogen plant tariff may please be allowed as per generic tariff allowed 

by the Hon‟ble commission for the biomass plants in continuation to the existing 

practice. Further for SHP Gangrel, Sikasar, & SHP Korba west, the ARR as allowed 

Page 34



vide MYT order for FY 12-13 may please be continued and the tariff may be allowed 

in the same manner as was done in MYT order. 

It is to submit that on various issues related to detailed Tariff order 

dated.30.04.2011 CSPGCL submitted detailed representation vide letter dated 

01.06.2011.Among the issues raised therein, only one issue regarding pension fund 

contribution has been redressed. It is requested that cognizance of issued raised 

may be taken in course of instant petition. 

PRAYER 

In light of the above submissions the petitioner, therefore prays that the Hon‟ble 

Commission may please: 

1. Approve provisional true up claim of CSPGCL on actual as submitted above. 

2. Approve plant performance as prayed herein above. 

3. Reset the tariff for FY 12-13 for the plants as prayed herein above by the 

petitioner. 

4. The impact of fuel cost variance may be allowed in accordance to prevailing 

regulation and Hon‟ble APTEL decision dt 11 th November 2011. 

5. The petition filing fee and publication expenses may please be allowed. 

6. Condone any inadvertent omissions/ errors/ shortcomings and permit the 

Petitioner to add/ change/ modify/ alter this petition and make further 

submissions as may be required at a future date. 

7. Pass such other and further relief as may be deemed fit and proper in the 

circumstances of the case. 


Through 

Place : Raipur 

Date : 

S. K Tiwari 

S.E. O/o C.E. (C&CP) 

CSPGCL, Raipur 

Page 35

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