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Consultation Paper on Setting Tariffs
               for the
         Period 2011-2015




      Public Utilities Commission of Sri
                     Lanka




Consultation Paper on Setting Tariffs for the period 2011-2015   1
Consultation Paper on Setting Tariffs for the
                                  Period 2011-2015




                                                   TABLE OF CONTENTS




1. PREAMBLE ............................................................................................................................................................... 5

2. INVITATION FOR PUBLIC COMMENTS ......................................................................................................... 6

3. ALLOWED REVENUES FOR LICENSEES ........................................................................................................ 7
   3.1 SALES FORECAST AND ALLOWED LOSSES .......................................................................................................... 7
     3.1.1 Sales Forecast and Losses filed by Licensees ........................................................................................... 7
     3.1.2 Adjusted Sales Forecast and Allowed Losses ........................................................................................... 7
   3.2 ALLOWED COSTS OF LICENSEES ...................................................................................................................... 10
     3.2.1 Debt Restructuring of CEB Licensees ..................................................................................................... 10
     3.2.2 Costs of Distribution Licensees ............................................................................................................... 10
     3.2.3 Costs of the Transmission Licensee......................................................................................................... 14
     3.2.4 Revenue Requirements of the Single Buyer ............................................................................................. 15
     3.2.5 Non-dispatchable Renewable Energy Power Plants .............................................................................. 17
     3.2.6 Allowed Revenues of the Single Buyer .................................................................................................... 18
     3.2.7 Provision for the Settlement of Short-term Debts ................................................................................... 18
   3.3 ANALYSIS OF COSTS OF LICENSEES ................................................................................................................. 19
4. GOVERNMENT SUBSIDIES................................................................................................................................ 20
   4.1       LONG-TERM DEBTS WRITTEN-OFF AND RESCHEDULED ................................................................................... 20
   4.2       CONCESSIONS ON FUEL PRICES ........................................................................................................................ 21
   4.3       PROCEDURE IF SUBSIDIES OR CONCESSIONS ARE CHANGED ........................................................................... 21
5. ROAD MAP FOR TARIFF REBALANCING .................................................................................................... 22
   5.1       INTRODUCTION ................................................................................................................................................ 22
   5.2       THE ROAD MAP FOR TARIFF REFORMS ............................................................................................................. 22
   5.3       TIME INTERVALS PROPOSED FOR TOU TARIFFS .............................................................................................. 23
6. PROPOSED TARIFFS ........................................................................................................................................... 24
   6.1       LEVY ON STREET LIGHTING ............................................................................................................................. 24
   6.2       PROPOSED TARIFFS FOR 2011 .......................................................................................................................... 25
   6.3       FORM OF THE MONTHLY STATEMENT OF ACCOUNT ......................................................................................... 26

7. CONCLUSION ........................................................................................................................................................ 27




Consultation Paper on Setting Tariffs for the period 2011-2015                                                                                                          2
LIST OF TALBLES
Table 1- Sales Forecasts and Loss Allowances Filed by Distribution Licensees ................................. 7

Table 2- Sales Forecast and Loss Allowances Filed by the Transmission Licensee ............................ 7

Table 3- Allowed Sales, Purchases and Losses ............................................................................ 8

Table 4- Distribution and Retail Revenues Filed and Allowed Revenues .........................................12

Table 5- Transmission and BSOB Revenues Filed and Allowed Revenues .......................................15

Table 6- Filed and Allowed Payments to Non-dispatchable NCRE Power Plants ...............................17

Table 7- Allowed Revenue of the Single Buyer (incl Transmission and BSOB) .................................18

Table 8-Filed Provisions to Settle Short-term Debts of CEB Licensees ...........................................18

Table 9- Analysis of Allowed Costs of Transmission and Distribution Services ................................19

Table 10- Composition of the Costs to end-users (January - June 2011) .......................................20

Table 11- Analysis of the Cost Break-up of end-users .................................................................20

Table 12- Evaluation of the Government Subsidy owing to Long-term Debt Relief ..........................20

Table 13- Composition of Costs including Government Subsidies..................................................21

Table 14- Costs of Supply and Subsidies Required in Year 2011 if Present Tariffs Continue..............22

Table 15- Approved Roadmap for Tariff Rebalancing ...................................................................22

Table 16- Proposed Intervals in the TOU Tariff ...........................................................................23

Table 17- Allowed Energy Sold to Approved Street Lighting to be Recovered through the Levy for year
2011 ....................................................................................................................................24

Table 18- Existing Tariffs and Proposed Tariffs for January-June 2011 ..........................................25

Table 19- Proposed Form of the Monthly Statement of Account (LV Customers) .............................26

Table 20- Proposed Form of the Monthly Statement of Account (LV bulk and MV customers) ...........27




Consultation Paper on Setting Tariffs for the period 2011-2015                                                                         3
List of Abbreviations


           BSOB                      Bulk Supply and Operations Business
           BST                       Bulk Supply Tariff
           CAPEX                     Capital Expenditure
           CEB                       Ceylon Electricity Board
           DL                        Distribution Licensee
                                     Distribution and Supply Licensee for CEB Distribution
           DL1
                                     Region 1
                                     Distribution and Supply Licensee for CEB Distribution
           DL2
                                     Region 2
                                     Distribution and Supply Licensee for CEB Distribution
           DL3
                                     Region 3
                                     Distribution and Supply Licensee for CEB Distribution
           DL4
                                     Region 5
           DL5                       Distribution and Supply Licensee LECO
           FSA                       Fuel Supply Agreement
                                                        Licensee
           CEB GL                    CEB Generation
           GWh                       Giagawatt hour
           kVA                       kilovolt ampere
           kW                        kilowatt
           kWh                       kilowatt hour
           LECO                      Lanka Electricity Company (Pvt) Ltd.
           LKR                       Sri Lanka Rupee
           LV                        Low Voltage
           MV                        Medium Voltage
           MWh                       Megawatt hour
           NCRE                      Non-Conventional Renewable Energy
           O&M                       Operations & Maintenance
           OPEX                      Operating Expenditure
           PPA                       Power Purchase Agreement
           SPPs                      Small Power Producers
           TL                        Transmission and BSOB Licensee
           TOU                       Time of Use
           VAT                       Value Added Tax
           WIP                       Work-in-Progress




Consultation Paper on Setting Tariffs for the period 2011-2015                               4
Consultation Paper on Setting Tariffs for the
                                Period 2011-2015

1. PREAMBLE

This consultation paper is issued under Section 30 of the Sri Lanka Electricity Act No 20 of 2009 (the
“Act”), for the purpose of allowing consumers and other interested parties to participate in setting the
tariffs in accordance with the cost-reflective methodology approved by the Commission.

In accordance with Section 32(2)(a) of the Act, the Commission, on 26th July 2010, approved a cost-
reflective Methodology for Tariffs and subsequently issued the same to the Transmission Licensee
and all the Distribution Licensees . The Methodology for Tariffs issued to the Licensees is available as
a separate document . The methodology has the following key features:
                      1



    (i)       The purchase of generation by the Transmission and Bulk Supply Licensee (the “Single
              Buyer”) will be passed-through to the Distribution and Supply Licensees, and thereby to the
              end-use customers. The revision period for such approved generation pass-through costs will
              be once in six months.
    (ii)      Tariffs chargeable by the Transmission and Bulk Supply Operations Business of the
              Transmission Licensee will be based on multi-year tariff principles, where the Base Allowed
              Revenue for the Transmission Licensee will be capped at the same price each year for the
              entire Tariff Period (“a fixed revenue cap”), subject to (a) allowances when large transmission
              capital investments are commissioned, allowed as and when such events occur, and (b)
              annual adjustments to the Base Allowed Revenue on account of inflation and exchange rate
              variations.
    (iii)     Tariffs chargeable by the Distribution and Supply Licensees for the Distribution and Supply
              business will be based on multi-year tariff principles, where the Base Allowed Revenue for
              each Distribution Licensee will be capped but vary from year to year over the Tariff Period (“a
              variable revenue cap”), subject to annual adjustments to the Base Allowed Revenue on
              account of inflation and exchange rate variations, and variations of the number of customers
              and amount of energy sold.
    (iv)      The Commission has determined that (a) the first six-month period for the determination of
              generation pass-through costs would commence on 1st January 2011, and that (b) the first
              Tariff Period for the determination of Transmission Licensee’s and Distribution Licensees’
              allowed revenues to be five years commencing on 1st January 2011.
    (v)       To reflect the variations in the allowed generation pass-through costs in each six-month
              interval, and the Transmission and Distribution allowed revenues once in 12-months, the end-
              use customer tariffs would be changed once in six months.
    (vi)      Owing to the limited information available to the Commission to assess the Licensees’ revenue
              requirements, the Commission has determined that there will be an extraordinary tariff filing
              by the Transmission Licensee and Distribution Licensees on or before 30th June 2011, for the
              remaining period of the first Tariff Period (ie 2012-2015), by which time, certified information
              including audited statement of accounts for each Licensee should be filed with the Commission
    (vii)     Owing to the requirement to maintain uniform national tariffs to end-use customers,
              irrespective of varying costs of each Distribution Licensee, the Commission requested each
              Licensees to file only their revenue requirements. Once the revenue requirements are
              reviewed and approved, the Commission has used such Allowed Revenues to develop the
              proposed end-use customer tariffs.

The Commission approved and issued the following time table for the setting of tariffs:

             Submission of revenue requirements by the Licensees for the first Tariff Period: 9th
              September 2010 (completed)
             Analysis of revenue requirements, clarifications by Licensees and preparation of the
              Commission’s proposals: 14th October 2010 (completed)
             Period allowed for Public Consultations: 24rd November to 08th December 2010
             Public hearing: 15th December 2010
             Operational date for new tariffs: 1st January 2011


In fulfilling the relevant sections of Condition 32 of the Transmission and the Bulk Supply License No
EL/T/09-002 issued to the Ceylon Electricity Board (CEB), the Transmission Licensee (hereinafter
referred to as the TL) has submitted the revenue requirements for the period starting January 2011.



    available upon request to the Commission or it may be downloaded from www.pucsl.gov.lk
1



Consultation Paper on Setting Tariffs for the period 2011-2015                                             5
In fulfilling the relevant section of Condition 31 of Electricity Distribution and Supply Licenses, the five
Licensees namely


  (i)     Ceylon Electricity Board in respect of Region 1 holding license number EL/D/09-003
          (hereinafter referred to as DL1)
  (ii)    Ceylon Electricity Board in respect of Region 2 holding license number EL/D/09-004
          (hereinafter referred to as DL2)
  (iii)   Ceylon Electricity Board in respect of Region 3 holding license number EL/D/09-005
          (hereinafter referred to as DL3)
  (iv)    Ceylon Electricity Board in respect of Region 4 holding license number EL/D/09-006
          (hereinafter referred to as DL4)
  (v)     Lanka Electricity Company (Private) Limited holding license number EL/D/09-007 (hereinafter
          referred to as DL5)

have submitted their respective revenue requirements for the five year period commencing January
2011.
This consultation document is in six parts. The second part presents the key issues on which the
Commission invites public comments and the mode in which such comments would be received. The
third part presents the Allowed Revenues to each Licensee. The fourth part presents an analysis of
Government Subsidies to the sector. The Road Map for Tariff Restructuring and Re-balancing is
presented next, to achieve cost-reflective tariffs over 2011-2015. Finally, the sixth part provides the
cost of supply of electricity to each customer category, the subsidies and surcharges, and the end-use
customer tariffs proposed by the Commission for the first six-month period commencing 1st January
2011.


2. INVITATION FOR PUBLIC COMMENTS
The Commission invites public comments on the following specific proposals listed under each part of
this consultation document.

Allowed Revenues for each Licensee
For the Transmission Licensee and for each Distribution Licensee,
(i) The sales forecast and allowed losses of each Licensee’s network (2011-2015)
(ii) Allowed revenues for each Licensee (2011-2015)
(iii) Allowed provision for energy sold for street lighting (2011-2015)
For the Transmission Licensee
(iv) Allowed costs of purchases from generation
(v) Allowed provision for purchases from non-dispatchable non-conventional renewable energy-
     based generating facilities above the avoided costs of other power plants of the generating
     system
Road Map for Tariff Restructuring and Rebalancing
(vi) Tariff restructuring in each year to move the customer tariffs towards cost-reflective tariffs
(vii) The time intervals proposed for the implementation of mandatory Time of Use (TOU) tariffs
(viii) The target of moving the electricity sector to break-even by year 2014 and to profitability by
       2015.
Tariffs Payable by Customers from 1st January 2011
(ix) The Tariff Schedule
(x) Contents of the monthly statement of account



Public comments may be sent by post or delivered by hand to: Public Utilities Commission of Sri
Lanka, Level 6, BOC Merchant Tower, No. 28, St. Michael’s Road, Colombo 03.

Comments may also be sent on email to: tariff@pucsl.gov.lk




Consultation Paper on Setting Tariffs for the period 2011-2015                                           6
3. ALLOWED REVENUES FOR LICENSEES

     3.1 SALES FORECAST AND ALLOWED LOSSES

Forecast sales of electricity and the allowed losses in transmission and distribution have an impact on
the investments and operating costs of licensees, and on the pass-through costs of electricity
generation, all of which will impact the end-use customer tariffs.

           3.1.1     SALES FORECAST AND LOSSES FILED BY LICENSEES
Sales forecasts, purchases from the Transmission Licensee (TL) and the loss allowances filed by the
Distribution Licensees (DLs) are shown in Table 1. Sales to DLs, purchases from generation and loss
allowances filed by the TL are shown in Table 2.

             Table 1- Sales Forecasts and Loss Allowances Filed by Distribution Licensees

                   DL1                      DL2                      DL3                     DL4                       DL5
                  As filed                 As filed                 As filed                As filed                  As filed
    Year Purchases Sales     Loss Purchases Sales     Loss Purchases Sales     Loss Purchases Sales      Loss Purchases Sales    Loss
           (GWh)    (GWh)           (GWh)    (GWh)           (GWh)    (GWh)           (GWh) (GWh)               (GWh)    (GWh)

    2009    2,663    2,354   11.6%   3,208    2,734   14.8%   2,033   1,809    11.0%    1,764    1,544   12.5%   1,120   1,030   8.1%
    2010    2,849    2,519   11.6%   3,421    2,925   14.5%   2,175   1,936    11.0%    1,850    1,628   12.0%   1,232   1,132   8.1%
    2011    3,003    2,673   11.0%   3,670    3,156   14.0%   2,348   2,090    11.0%    1,868    1,644   12.0%   1,276   1,172   8.1%
    2012    3,199    2,847   11.0%   3,899    3,361   13.8%   2,501   2,226    11.0%    1,990    1,751   12.0%   1,321   1,214   8.1%
    2013    3,406    3,032   11.0%   4,143    3,580   13.6%   2,664   2,371    11.0%    2,119    1,865   12.0%   1,367   1,256   8.1%
    2014    3,628    3,229   11.0%   4,402    3,812   13.4%   2,837   2,525    11.0%    2,257    1,986   12.0%   1,413   1,298   8.1%
    2015    3,864    3,439   11.0%   4,667    4,060   13.0%   3,021   2,689    11.0%    2,390    2,115   11.5%   1,459   1,341   8.1%

Notes: Loss are given as a % of purchases by each licensee




            Table 2- Sales Forecast and Loss Allowances Filed by the Transmission Licensee
                                       Year        Sales        Input to TL       Losses filed
                                                 forecast       filed by TL       by TL (as a
                                                 filed by          (GWh)          % of input)
                                                TL (GWh)
                                       2010       10,347          10,634               2.70%
                                       2011       10,890          11,185               2.64%
                                       2012       11,559          11,917               3.00%
                                       2013       12,266          12,645               3.00%
                                       2014       13,022          13,424               3.00%
                                       2015       13,802          14,229               3.00%




           3.1.2     ADJUSTED SALES FORECAST AND ALLOWED LOSSES
The following corrections were made to the licensee loss allowances:

(a) The Commission reviewed the losses filed for year 2009. The filed sales of CEB DLs was
    8441 GWh (including sales to DL5- LECO). On the basis that TL’s losses in year 2009 were 2.7%,
    the calculated input to the TL’s network would be 9936 GWh. Therefore, the total CEB licensees’
    (TL, and DL1, 2, 3 and 4) network loss for 2009 as a share of input to TL would be 15.0%. With
    the addition of power plant auxiliary power requirements and power plant step-up transformer
    losses, CEB reported elsewhere, that the total loss was 14.6%, which is significantly lower than
    the 15.0% transmission and distribution loss implied in the filed losses. This mismatch was
    corrected by reducing the allowed losses of all CEB DLs for 2009.

(b) The Commission observes the even with the above corrections, the total transmission and
    distribution network loss of Sri Lanka for year 2009 is estimated to have been 14.2%, which fell
    short of the policy target of 13.5% in 2009 established in the National Energy Policy and
    Strategies .
               2




2
  National Energy Policy and Strategies, The Gazette of the Democratic Socialist Republic of Sri Lanka,
Extraordinary, No. 1553/10 – TUESDAY, JUNE 10, 2008


Consultation Paper on Setting Tariffs for the period 2011-2015                                                                   7
(c)    The uncorrected losses (as filed) for the total transmission and distribution network in 2015 was
       14.4%. The corrected losses indicate a total network loss of 13.3% in 2015. A target of 12% of
       transmission and distribution losses (as a share of net generation) has been established for year
       2016, in the Government’s ten-year plan . Therefore, allowed losses of all distribution licensees
                                                  3

       were further adjusted downwards, to enable a target transmission and distribution loss of 12.1%
       to be met by year 2015.

(d) The losses of the TL as a share of input to the TL’s network were allowed as filed.

The following corrections were made to the licensee sales forecasts:

(e) The sales forecast filed by the TL for 2012-2015 did not match with the purchases filed by DL1,
    2, 3 and 4, who are direct customers of TL. This mismatch was corrected, considering at this
    stage, that DLs’ purchase forecasts are correct.

(f)    The sale growth forecasts for DL1, 2, 3 and 4 for year 2010 were in the range of 5.5% to 7.0%,
       whereas DL5 forecast a 9.9% growth. Sales by DL1, 2, 3 and 4 were increased to represent a
       more realistic 7.9% growth for all sales in Sri Lanka in year 2010.

(g) DL5 has filed some of the sales for street lighting as losses. Based on the response to a
    clarification, this was corrected and identified under sales.

(h) DL4 has filed a lower sales growth for year 2011 of 1.0%, which was corrected to 5.0%.

Accordingly, in setting tariffs, the Commission proposes to establish the allowed forecast and allowed
losses as shown in Table 3.

                            Table 3- Allowed Sales, Purchases and Losses
                                                     DL1
                         As filed                                        Corrected
Year
         Purchases     Sales         Sales   Loss          Purchases    Sales     Sales   Allowed
          (GWh)       (GWh)         growth                  (GWh)      (GWh)     growth     loss
2009       2,663        2,354                11.6%           2,614       2,354            10.0%
2010       2,849        2,519       7.0%     11.6%           2,828       2,547    8.2%    10.0%
2011       3,003        2,673       6.1%     11.0%           2,983       2,704    6.2%     9.3%
2012       3,199        2,847       6.5%     11.0%           3,164       2,882    6.6%     8.9%
2013       3,406        3,032       6.5%     11.0%           3,360       3,071    6.6%     8.6%
2014       3,628        3,229       6.5%     11.0%           3,568       3,272    6.5%     8.3%
2015       3,864        3,439       6.5%     11.0%           3,797       3,486    6.5%     8.2%


                                                     DL2
                         As filed                                        Corrected
Year
         Purchases     Sales         Sales   Loss          Purchases    Sales     Sales   Allowed
          (GWh)       (GWh)         growth                  (GWh)      (GWh)     growth     loss
2009       3,208        2,734                14.8%           3,149       2,734            13.2%
2010       3,421        2,925       7.0%     14.5%           3,396       2,958    8.2%    12.9%
2011       3,670        3,156       7.9%     14.0%           3,645       3,193    8.0%    12.4%
2012       3,899        3,361       6.5%     13.8%           3,858       3,403    6.6%    11.8%
2013       4,143        3,580       6.5%     13.6%           4,074       3,626    6.6%    11.0%
2014       4,402        3,812       6.5%     13.4%           4,311       3,863    6.5%    10.4%
2015       4,667        4,060       6.5%     13.0%           4,573       4,116    6.5%    10.0%




3
 A Ten-year Horizon Development Framework 2006-2016, Department of National Planning, Ministry of Finance
and Planning


Consultation Paper on Setting Tariffs for the period 2011-2015                                        8
DL3
                         As filed                                        Corrected
Year
       Purchases       Sales         Sales   Loss          Purchases    Sales     Sales      Allowed
        (GWh)         (GWh)         growth                  (GWh)      (GWh)     growth        loss
2009     2,033          1,809                11.0%           1,995       1,809                9.3%
2010     2,175          1,936       7.0%     11.0%           2,159       1,957    8.2%        9.3%
2011     2,348          2,090       8.0%     11.0%           2,332       2,115    8.1%        9.3%
2012     2,501          2,226       6.5%     11.0%           2,474       2,253    6.6%        8.9%
2013     2,664          2,371       6.5%     11.0%           2,627       2,401    6.6%        8.6%
2014     2,837          2,525       6.5%     11.0%           2,790       2,558    6.5%        8.3%
2015     3,021          2,689       6.5%     11.0%           2,969       2,726    6.5%        8.2%


                                                     DL4
                         As filed                                        Corrected
Year
       Purchases       Sales         Sales   Loss          Purchases    Sales     Sales      Allowed
        (GWh)         (GWh)         growth                  (GWh)      (GWh)     growth        loss
2009     1,764          1,544                12.5%           1,732       1,544               10.9%
2010     1,850          1,628       5.5%     12.0%           1,836       1,646    6.6%       10.4%
2011     1,868          1,644       1.0%     12.0%           1,930       1,730    5.1%       10.4%
2012     1,990          1,751       6.5%     12.0%           2,051       1,843    6.6%       10.1%
2013     2,119          1,865       6.5%     12.0%           2,173       1,964    6.6%        9.6%
2014     2,257          1,986       6.5%     12.0%           2,305       2,093    6.5%        9.2%
2015     2,390          2,115       6.5%     11.5%           2,440       2,230    6.5%        8.6%


                                                     DL5
                         As filed                                        Corrected
Year
       Purchases       Sales         Sales   Loss          Purchases    Sales     Sales      Allowed
        (GWh)         (GWh)         growth                  (GWh)      (GWh)     growth        loss
2009     1,120          1,030                8.1%            1,120       1,051                6.2%
2010     1,232          1,132       9.9%     8.1%            1,231       1,155    9.9%        6.2%
2011     1,276          1,172       3.6%     8.1%            1,273       1,198    3.7%        5.9%
2012     1,321          1,214       3.6%     8.1%            1,314       1,241    3.6%        5.6%
2013     1,367          1,256       3.5%     8.1%            1,357       1,284    3.5%        5.4%
2014     1,413          1,298       3.3%     8.1%            1,399       1,327    3.3%        5.2%
2015     1,459          1,341       3.3%     8.1%            1,442       1,370    3.3%        5.0%


                                                     TL
                         As filed                                        Corrected
Year
       Purchases       Sales       Sales     Loss          Purchases    Sales     Sales      Allowed
        (GWh)         (GWh)       growth                    (GWh)      (GWh)     growth        loss
2009                                                         9,754       9,491                2.7%
2010     10,347       10,634                 2.7%           10,503      10,219    7.7%        2.7%
2011     10,890       11,185        5.2%     2.6%           11,185      10,890    6.6%        2.6%
2012     11,559       11,917        6.5%     3.0%           11,903      11,546    6.0%        3.0%
2013     12,266       12,645        6.1%     3.0%           12,612      12,233    6.0%        3.0%
2014     13,022       13,424        6.2%     3.0%           13,375      12,974    6.1%        3.0%
2015     13,802       14,229        6.0%     3.0%           14,206      13,780    6.2%        3.0%


                                        Total TL and all DL networks                                   Policy
                        As filed                                          Corrected                    target
        Sales to      Sales      Input to      Sri        Sales to      Sales     Input to     Sri     for Sri
Year
        End-use      growth        TL's     Lanka         End-use      growth       TL's     Lanka     Lanka
       Customers                 network      T&D        Customers                network     T&D       T&D
         (GWh)                    (GWh)       Loss         (GWh)                   (GWh)      Loss     losses
2009     8,351                                              8,371             -    9,754     14.2%     13.5%
2010     8,908        6.7%        10,634    16.2%          9,031        7.9%       10,503    14.0%
2011     9,460        6.2%        11,185    15.4%          9,667        7.0%       11,185    13.6%
2012    10,078        6.5%        11,917    15.4%          10,308       6.6%       11,903    13.4%
2013    10,736        6.5%        12,645    15.1%          10,989       6.6%       12,612    12.9%
2014    11,437        6.5%        13,424    14.8%          11,713       6.6%       13,375    12.4%
2015    12,184        6.5%        14,229    14.4%          12,485       6.6%       14,206    12.1%     12.1%
2016                                                                                                   12.0%




Consultation Paper on Setting Tariffs for the period 2011-2015                                            9
3.2 ALLOWED COSTS OF LICENSEES

The Commission observes that the present tariff setting is the first such setting of tariffs after the
licenses were issued in October 2009. Four of the five licenses for distribution are held by Ceylon
Electricity Board (CEB). The Transmission License is also held by CEB. As CEB operated as a single,
vertically integrated utility until the licenses were issued, annual accounts of the functional business
units that hold each license have not been previously prepared. A condition in the license is the
requirement to prepare and submit audited accounts annually to the Commission. Similarly, the
capital expenditure program for at least five years ahead is required to be submitted to the
Commission for approval.

In this Tariff Setting, the Commission intends to waive these two requirements, and has determined
that, (a) a capital expenditure program should be filed by each licensee for Commission approval, by
March 2011, (b) annual audited accounts of year 2010 should be submitted by each licensee by June
2011, and considering the limitation of information currently available for the current tariff setting
that, (c) an extraordinary tariff setting will be conducted in 2011 in which the licensees would file
their revenue requirements for the period 2012-2015 for the approval of the Commission.

     3.2.1       DEBT RESTRUCTURING OF CEB LICENSEES
Prior to commencing the tariff setting and associated procedures, the Commission conducted a
detailed assessment of likely costs of each licensee, including the costs of generation, and made such
information available to the Ministry of Finance and Planning, and to the Ministry of Power and
Energy. The analysis indicated that CEB licensees would continue to make losses if the present Tariff
Order of the Commission, issued in April 2009, continues to be applied.

In June 2010, the Commission provided several scenarios of reforms to customer tariffs, to enable
the licensees to move to profitability over the period 2011-2015. The Commission observed that the
costs of generation would continue to increase in real terms until 2013, and would decline thereafter,
with the commissioning of stages 2 and 3 of the Puttalam coal-fired power plant and the Trincomalee
coal-fired power plant. The Commission thus briefed the Government (i) on the large burden of
servicing the debts of DL1, 2, 3, 4 and the TL, and (ii) the need to cushion the costs of the CEB
licensees, directly or indirectly, if their impacts on customer prices are to be managed within
reasonable limits, particularly over 2011-2013.

In assessing the costs of debt, the Commission is guided by the certified minutes of a meeting held at
the Ministry of Finance and Planning on August 6, 2010, chaired by Secretary to the Treasury. The
minutes have been circulated to all the CEB licensees and the Commission. The minutes state, under
item (3) a. “Total outstanding debt stock (of CEB licensees) to the Treasury and (Ceylon
Petroleum Corporation) CPC as at 31.12.2009 should be considered as zero. In other
words, as at 01.01.2010 CEB has no outstanding debt”. Under the same treasury meeting
referred to above, it is noted under item (3) c. “The servicing of debt including repayment of
capital and interest for the investment of about US$3bn (made by the government) during
the period from 01.01.2010 – 31.12.2013 should be borne by CEB. However, CEB need not
bear the cost of interest for the investment made by the government prior to 31.12.2009.
Until a decision is taken, for the purpose of the tariff calculation the interest cost should
not be considered”.

The Commission therefore, requested CEB licensees to take note of the above when filing their
revenue requirement for the period 2011-2015.

The Government, however, has not provided guidance on restructuring of CEB licensees’ short-term
debts.


     3.2.2       COSTS OF DISTRIBUTION LICENSEES
The five distribution licensees were provided with a template to submit their costs. The template
follows the principles stated in the approved Methodology for Tariffs. In addition, the licensees were
requested for additional supporting information.

Initially, all the templates were corrected for inaccuracies in formulae. Thereafter, supporting
information provided by each licensee was evaluated and the required adjustments were made to the
costs. The following is a list of such adjustments done.


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Distribution Licensees (DL1, 2, 3 and 4):

(i)     Long term debts: These commitments (capital repayments and interest payable thereon, and
        interest during construction on loans for on-going capital expenditure projects) had been filed by
        CEB licensees, in spite of the debt restructuring plan stipulated by the Government (see section
        3.2.1). These were removed from the filed costs, and the Licensees were requested to provide a
        schedule of restructured debts that would be required to be serviced from 2014 onwards. This
        schedule has not been received, and therefore, the present tariff setting has no provision for
        servicing long-term debts even after the debt moratorium allowed by the Treasury explained in
        section 3.2.1 ends in 2013. The Commission proposes to consider any such debts filed and
        associated interest payments, during the extraordinary tariff setting scheduled to commence in
        June 2011, if the details of such debts are filed.

(ii) Short-term debts: Licensees have filed the cost of repayment of short-term debts, as
     “headquarters overheads”. The Commission observes that such inclusion would cause the
     distribution licensee costs to be distorted. The Commission proposes to include such debt
     recovery as a levy under the generation pass-through costs (please see further details in section
     3.2.7).

(iii) Other revisions:
      (a) Operating expenditure (OPEX) and capital expenditure (CAPEX) were mixed in certain filings,
          and these were adjusted accordingly. Similarly, VAT and customs duty components associated
          with such expenditure were adjusted.
      (b) The salary increase of 21.6% included in the filing was allowed for year 2012, considering the
          submission that salaries have not been increased in 2010. Thereafter, the salaries remain
          constant until 2014. From 2015 onwards, salary increases have been adjusted to be 3.5% in
          real terms. The same was applied in assessing the costs of salaries at the headquarters of
          each licensee.
      (c) Non Salary OPEX was adjusted to increase at the same rate as the customer growth
          percentage filed by the licensees.
      (d) The non-salary overhead I (Regional Head Quarters Overhead) costs of licensees have been
          corrected to remain constant in real terms throughout the tariff period, at the level filed for
          2010.
      (e) Following information obtained from licensees, the non-amortized customer contribution was
          removed from the asset base and included as a separate line item in the revenue template for
          calculations
      (f) The filed CAPEX allowance for new vehicles was decreased by 50% (from 2011 onwards) as an
          interim measure, pending a comprehensive review during the approval process of the CAPEX
          program due in March 2011. The forecast depreciation was adjusted accordingly.
      (g) OPEX of the retail business was adjusted to increase at the same rate as the customer growth
          percentage
      (h) Income from sales to street lighting was removed from bad debts.

Distribution licensee DL5:
      (i) Salaries of DL5 (LECO) were allowed a 8.5% real increase in 2011, and thereafter, a 3.5% real
          increase annually over 2012-2015 was allowed.
      (j) Non Salary OPEX was adjusted to increase at the same rate as the customer growth
          percentage filed by the licensees.
      (k) The non-salary Head Quarters overhead costs have been corrected to remain constant in real
          terms throughout the tariff period, at the level filed for 2010.
      (l) Following information obtained from the licensee, the non-amortized customer contribution
          was removed from the asset base and included as a separate line item in the revenue template
          for calculations
      (m) CAPEX allowance for new vehicles have been decreased by 50% as an interim measure,
          pending a comprehensive review during the approval process of the CAPEX program due in
          March 2011. The depreciation forecast was adjusted accordingly.
      (n) OPEX of the retail business was adjusted to increase at the same rate as the customer growth
          percentage
      (o) Bad debts were adjusted by taking out the sales to street lighting, as provided by the licensee,
          and added that component as sales.



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Filed Revenue Requirements and Allowed Revenues proposed by the Commission are summarised in
Table 4.

                 Table 4- Distribution and Retail Revenues Filed and Allowed Revenues

                                                                                      As filed by the Licensee
Distribution Licensee 1 (DL1)                    Unit          2011         2012         2013        2014         2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap            LKR million      8,014.4      8,384.5      8,750.6     9,113.5       9,511.0
Retail Service Allowed Revenue
Retail Service Price Cap                   LKR/customer         428.4        428.4        428.4       428.4         428.4
Total Revenue Summary
Distribution                                 LKR million       8,014.4      8,384.5      8,750.6     9,113.5       9,511.0
Retail Service                               LKR million         550.8        576.4        602.5      626.8          655.2
TOTAL                                        LKR million      8,565.2      8,960.9      9,353.1     9,740.3      10,166.3


Distribution revenue per MWh sold             LKR/MWh          2,963.9      2,909.3      2,849.4     2,785.3       2,728.4
Distribution revenue per customer served    LKR/customer       6,234.5      6,214.0      6,214.5     6,233.9       6,233.8


                                                                                      Proposed by the Commission
Distribution Licensee 1 (DL1)                    Unit          2011         2012         2013        2014         2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap            LKR million      6,423.2      6,719.9      7,013.3     7,304.1       7,622.7
Retail Service Allowed Revenue
Retail Service Price Cap                   LKR/customer         433.7        433.7        433.7       433.7         433.7
Total Revenue Summary
Distribution                                 LKR million       6,423.2      6,719.9      7,013.3     7,304.1       7,622.7
Retail Service                               LKR million         557.7        583.3        609.9      634.7          663.6
TOTAL                                        LKR million      6,980.9      7,303.2      7,623.2     7,938.8       8,286.4


Distribution revenue per MWh sold             LKR/MWh          2,375.4      2,331.7      2,283.7     2,232.3       2,186.7
Distribution revenue per customer served    LKR/customer       4,996.7      4,980.3      4,980.7     4,996.3       4,996.1
                                           All renevues are in constant January 2011 currency


                                                                                      As filed by the Licensee
Distribution Licensee 2 (DL2)                    Unit         2011          2012        2013        2014          2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap            LKR million     8,147.4      8,524.7      8,918.7      9,294.6       9,686.8
Retail Service Allowed Revenue
Retail Service Price Cap                      LKR/cust         551.2         551.2       551.2        551.2         551.2
Total Revenue Summary
Distribution                                  LKR million     8,147.4      8,524.7      8,918.7      9,294.6       9,686.8
Retail Service                                LKR million       835.1        870.2        917.0        959.8       1,004.3
TOTAL                                        LKR million     8,982.5      9,394.9      9,835.7     10,254.4      10,691.0


Distribution revenue per MWh sold             LKR/MWh         2,551.7      2,505.1      2,459.6      2,406.0       2,353.4
Distribution revenue per customer served    LKR/customer      5,377.9      5,359.0      5,339.7      5,350.7       5,362.0


                                                                                      Proposed by the Commission
Distribution Licensee 2 (DL2)                    Unit         2011          2012        2013        2014          2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap            LKR million     7,124.6      7,454.5      7,799.0      8,127.7       8,470.7
Retail Service Allowed Revenue
Retail Service Price Cap                      LKR/cust         544.7         544.7       544.7        544.7         544.7
Total Revenue Summary
Distribution                                  LKR million     7,124.6      7,454.5      7,799.0      8,127.7       8,470.7
Retail Service                                LKR million       831.0        863.6        907.5        945.1        984.3
TOTAL                                        LKR million     7,955.6      8,318.1      8,706.5      9,072.8       9,455.0


Distribution revenue per MWh sold             LKR/MWh         2,231.3      2,190.6      2,150.9      2,104.0       2,058.0
Distribution revenue per customer served    LKR/customer      4,702.8      4,686.2      4,669.3      4,679.0       4,688.9
                                                                         All renevues are in constant January 2011 currency




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As filed by the Licensee
Distribution Licensee 3 (DL3)                   Unit           2011        2012         2013        2014          2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap           LKR million      5,708.9      5,963.4      6,225.4     6,493.5        6,769.4
Retail Service Allowed Revenue
Retail Service Price Cap                     LKR/cust           405.6       405.6        405.6       405.6         405.6
Total Revenue Summary
Distribution                                 LKR million      5,708.9      5,963.4      6,225.4     6,493.5       6,769.4
Retail Service                               LKR million        448.6        464.0        486.0       509.5         533.0
TOTAL                                       LKR million      6,157.5      6,427.4      6,711.4     7,003.0        7,302.4


Distribution revenue per MWh sold            LKR/MWh          2,699.3      2,646.9      2,592.8     2,538.5       2,483.3
Distribution revenue per customer served   LKR/customer       5,181.1      5,173.1      5,172.1     5,176.0       5,185.6


                                                                                      Proposed by the Commission
Distribution Licensee 3 (DL3)                   Unit           2011        2012         2013        2014          2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap           LKR million      4,210.5      4,398.2      4,591.4     4,789.2        4,992.7
Retail Service Allowed Revenue
Retail Service Price Cap                     LKR/cust           401.4       401.4        401.4       401.4         401.4
Total Revenue Summary
Distribution                                 LKR million      4,210.5      4,398.2      4,591.4     4,789.2       4,992.7
Retail Service                               LKR million        446.3        460.7        481.8       502.8         524.2
TOTAL                                       LKR million      4,656.8      4,858.9      5,073.2     5,292.0        5,516.9


Distribution revenue per MWh sold            LKR/MWh          1,990.8      1,952.2      1,912.3     1,872.2       1,831.5
Distribution revenue per customer served   LKR/customer       3,821.2      3,815.3      3,814.6     3,817.5       3,824.5
                                                            All renevues are in constant January 2011 currency

                                                                                      As filed by the Licensee
Distribution Licensee 4 (DL4)                    Unit           2011        2012         2013        2014          2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap            LKR million       4,985.4     5,159.5      5,336.3     5,514.7       5,693.0
Retail Service Allowed Revenue
Retail Service Price Cap                      LKR/cust           477.1       477.1        477.1       477.1        477.1
Total Revenue Summary
Distribution                                  LKR million       4,985.4     5,159.5      5,336.3    5,514.7       5,693.0
Retail Service                                LKR million         359.7       398.7        412.5      425.1         443.9
TOTAL                                        LKR million       5,345.1     5,558.2      5,748.8     5,939.8       6,136.9


Distribution revenue per MWh sold              LKR/MWh          2,881.7     2,799.5      2,717.0    2,634.8       2,552.9
Distribution revenue per customer served     LKR/customer       6,074.1     6,151.0      6,237.0    6,332.2       6,437.8


                                                                                      Proposed by the Commission
Distribution Licensee 4 (DL4)                    Unit           2011        2012         2013        2014          2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap            LKR million       3,437.0     3,557.1      3,679.0     3,802.0       3,924.9
Retail Service Allowed Revenue
Retail Service Price Cap                      LKR/cust           436.1       436.1        436.1       436.1        436.1
Total Revenue Summary
Distribution                                  LKR million       3,437.0     3,557.1      3,679.0    3,802.0       3,924.9
Retail Service                                LKR million         338.5       368.9        377.5      385.5         393.0
TOTAL                                        LKR million       3,775.6     3,926.0      4,056.5     4,187.4       4,318.0


Distribution revenue per MWh sold              LKR/MWh          1,986.7     1,930.1      1,873.2    1,816.5       1,760.1
Distribution revenue per customer served     LKR/customer       4,187.7     4,240.6      4,299.9    4,365.6       4,438.4
                                                             All renevues are in constant January 2011 currency




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As filed by the Licensee
Distribution Licensee 5 (DL5)                   Unit          2011        2012        2013         2014         2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap           LKR million      2,377.7     2,441.7     2,505.3      2,568.5       2,631.3
Retail Service Allowed Revenue
Retail Service Price Cap                   LKR/customer        666.6       666.6       666.6        666.6        666.6
Total Revenue Summary
Distribution                                 LKR million     2,377.7      2,441.7     2,505.3     2,568.5       2,631.3
Retail Service                               LKR million       308.0        325.0       361.0       383.0         393.0
TOTAL                                       LKR million      2,685.7     2,766.7     2,866.3      2,951.5       3,024.3


Distribution revenue per MWh sold            LKR/MWh         1,984.7      1,967.5     1,951.2     1,935.6       1,920.7
Distribution revenue per customer served   LKR/customer      4,765.6      4,744.8     4,724.4     4,704.5       4,684.9


                                                                                    Proposed by the Commission
Distribution Licensee 5 (DL5)                   Unit          2011        2012        2013         2014         2015
Distribution Allowed Revenue
Distribution Variable Revenue Cap           LKR million      2,219.0     2,278.7     2,338.1      2,397.1       2,455.7
Retail Service Allowed Revenue
Retail Service Price Cap                     LKR/cust          595.9       595.9       595.9        595.9        595.9
Total Revenue Summary
Distribution                                 LKR million     2,219.0      2,278.7     2,338.1     2,397.1       2,455.7
Retail Service                               LKR million       295.5        302.7       325.0       332.2         324.4
TOTAL                                       LKR million      2,514.4     2,581.4     2,663.0      2,729.3       2,780.1


Distribution revenue per MWh sold            LKR/MWh         1,852.2      1,836.2     1,820.9     1,806.4       1,792.5
Distribution revenue per customer served   LKR/customer      4,447.5      4,428.1     4,409.0     4,390.4       4,372.2
                                                           All renevues are in constant January 2011 currency




      3.2.3      COSTS OF THE TRANSMISSION LICENSEE
The Transmission Licensee (TL) has two business operations, namely (i) the Transmission Business
(ii) the Bulk Supply and Operations Business (BSOB). In addition, the TL is also the Single Buyer,
purchasing from all the Generation Licensees (GLs). In this sub section, the Transmission and BSOB
businesses are discussed. The single buyer’s business is discussed in the next sub section.

Initially, the TL’s template was corrected for inaccuracies in formulae in the base template provided
by the Commission. Thereafter, supporting information provided by the TL was evaluated and the
required adjustments were made to the costs. The following is a list of such adjustments done.
(a) Long term debts: These commitments were removed on the same basis as for DL1, 2, 3 and 4,
    as previously explained.
(b) Short-term debts: These were removed to be included as a levy in the Single Buyer’s pass-
    through costs, as previously explained.
(c) Work-in-Progress: A large Work-in-progress (WIP) for on-going projects was observed. This was
    allowed, subject to certain projects on which information was not available. Projects that were not
    part of the transmission or BSOB, were removed. VAT and financial costs were adjusted accordingly.
(d) In OPEX, with the absence of detailed information, it was assumed that 50% of filed OPEX would be
    for salaries, which were allowed to escalate on the basis that a salary increase of 21.6% was
    allowed for year 2012, considering the submission that salaries have not been increased in 2010.
    Thereafter, the salaries remain constant until 2014. From 2015 onwards, salary increases have
    been adjusted to be 3.5% in real terms. The same was applied in assessing the costs of salaries
    at the headquarters of the licensee.
(e)It was assumed that 60% of the OPEX filed for Transmission Overheads were salaries, which were
allowed on the same basis as above.(f)CEB Corporate Overheads included a provision for the
settlement of short-term loans. This was removed as described earlier.




Table 5 shows the filed Revenue Requirements and Allowed Revenues proposed by the Commission.



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Table 5- Transmission and BSOB Revenues Filed and Allowed Revenues

                                                                                  As filed by the Licensee
                                              Unit          2011        2012        2013         2014         2015
   Transmission Allowed Revenue
   Transmission Revenue Cap                LKR million    9,293.7      9,293.7     9,293.7      9,293.7       9,293.7
   Bulk Supply and Operations Business
   Allowed Revenue
   BSOB Revenue Cap                        LKR million       207.0       207.0       207.0        207.0        207.0
   Total Revenue Summary
   Transmission                            LKR million     9,293.7      9,293.7     9,293.7     9,293.7       9,293.7
   BSOB                                    LKR million       207.0        207.0       207.0       207.0         207.0
   TOTAL                                   LKR million    9,500.7      9,500.7     9,500.7      9,500.7       9,500.7


   Revenue per MWh served                   LKR/MWh          830.9        779.9       735.0       692.3         653.2
   Revenue per kW                            LKR/kW        4,130.6      3,883.7     3,664.7     3,473.0       3,279.4


                                                                                  Proposed by the Commission
                                              Unit          2011        2012        2013         2014         2015
   Transmission Allowed Revenue
   Transmission Revenue Cap                LKR million    7,163.7      7,163.7     7,163.7      7,163.7       7,163.7
   Bulk Supply and Operations Business
   Allowed Revenue
   BSOB Revenue Cap                        LKR million       124.6       124.6       124.6        124.6        124.6
   Total Revenue Summary
   Transmission                            LKR million     7,163.7      7,163.7     7,163.7     7,163.7       7,163.7
   BSOB                                    LKR million       124.6        124.6       124.6       124.6         124.6
   TOTAL                                   LKR million    7,288.3      7,288.3     7,288.3      7,288.3       7,288.3


   Revenue per MWh served                   LKR/MWh          640.5        601.1       566.5       533.6         503.5
   Revenue per kW                         LKR/kW-year      3,183.9      2,993.6     2,824.8     2,677.0       2,527.8
                                                         All renevues are in constant January 2011 currency


     3.2.4        REVENUE REQUIREMENTS OF THE SINGLE BUYER
As stated in the approved Methodology for Tariffs, the Single Buyer costs are filed for a period of six
months (January to June). The Commission has the following observations and the corresponding
revisions were made to the filed revenues.

(a) Power Purchase Agreements (PPAs) between the Transmission Licensee and CEB
    Generation Licensee (CEB GL): PPAs between TL and CEB GL with respect to each power plant
    have not been submitted to the Commission for review and approval, as required in the
    Methodology for Tariffs. The Commission observes that depreciation of full generation assets has
    been included in the capacity charges of CEB GL’s power plants. As all the long-term debts have
    been written off or restructured, CEB GL has no debt repayment or interest commitments in year
    2011. Hence there is no justification to charge the full cost of depreciation on CEB GL’s power
    plants on customers.

    Therefore, the Commission proposes to remove the provision for depreciation included in CEB
    GL’s power plant capacity charges. Accordingly, a sum of LKR 6681 million estimated to have
    been filed as depreciation charges for year 2011 was removed from the Single Buyer’s filed
    generation capacity charges.

    However, the investments on these power plants may have included a certain amount of CEB’s
    equity, which has to be returned over a period of time. Based on information available to the
    Commission, the value of CEB generation assets were estimated to be LKR 267,000 million, on
    which CEB’s equity was assumed to be 20%. The Government or CEB have not indicated a desire
    to earn a return on equity on this investment.

    As a means of providing a return of equity (not return on equity) over a period of 40 years, a sum
    of 2.5% of the estimated equity was allowed annually. Accordingly, a sum of LKR 1336 million in

Consultation Paper on Setting Tariffs for the period 2011-2015                                                          15
2011 was provided for the purpose of return of equity, and added to the Single Buyer’s revenue
    requirements.

    The Commission reiterates that this is an interim arrangement, and that the process of filing the
    PPAs between CEB GLs and TL and approval by the Commission should be completed by 31st
    December 2010.

(b) Fixed O&M costs of CEB Power Plants: CEB thermal power plant capacity charges filed have a
    fixed, non-fuel energy charge of about LKR 2 per kWh. The Commission observes that this charge
    is excessive, but has been allowed pending a more comprehensive analysis during the approval of
    the CEB GL’s PPAs. The non-fuel energy charge filed for gas turbines at Kelanitissa were not
    allowed, owing to the low dispatch of the plant.

(c) Start-stop charges have been filed but estimates for the number of starts-stops have not been
    filed.

(d) Pricing of Petroleum fuels: Fuel Supply Agreements (FSA) were not filed with the Commission.
    TL provided the most recent invoices or communications with Ceylon Petroleum Corporation
    stating the prices, and these were used as the basis for fixing the prices of all petroleum fuels
    used for power generation.

(e) Coal pricing: The Fuel Supply Agreement (FSA) has not been submitted to the Commission.
    Therefore, the pricing was based on an invoice. The Commission observes the following: VAT has
    been included for coal, whereas for other fuels, VAT is not applicable. Therefore, VAT was
    removed from coal pricing. A sum of USD 5.65 per tonne has been included as depreciation and
    overheads within the price calculation for coal, for which the purpose is unclear. This was not
    allowed. A comprehensive pricing formula including any indices to which the pricing is linked,
    requires to be filed along with the next Single Buyer’s filing for the period July-December 2011.

(f) Hydropower Dispatch: The Single Buyer has not stated whether the filed hydropower dispatch
    would comply with the probability of occurrence of 70% stated in the Methodology for Tariffs. As
    the full claw-back provisions are available, the Commission has allowed the filed hydropower
    dispatch, pending further clarification in the extraordinary filing due in June 2011.

(g) Dispatch of the coal-fired power plant: The Commission observes that the coal-fired power
    plant, operating for the first time in the Tariff Period, has been dispatched only up to an annual
    capacity factor of 60%. This has been allowed, pending a complete review of the dispatch
    procedure and limitations before the next filing of the Single Buyer, after the power plant
    completes its commissioning and reliability testing over the first three months of year 2011.

(h) Un-dispatched power plant: The power plant GT07 has not been dispatched at all during the
    six-month period covered in the revenue filing of the Single Buyer, and the filing states that
    spares are not available. Capacity charges for this power plant have been filed, but were
    removed, pending a final decision by TL and submission of the relevant information to the
    Commission. An ex-post adjustment would be allowed for this power plant’s capacity charges,
    should the TL dispatch the power plant within the six-month period under consideration, but with
    prior approval of the relevant PPA by the Commission.

(i) IPPs not loaded to the rated plant capacity: Some IPPs are not loaded to the full capacity,
    stated as the “rated or installed capacity” in the respective PPAs submitted to the Commission.
    The Commission has allowed this situation, pending a final determination before the next filing by
    the TL for the Single Buyer’s costs.

(j) Northern Power: The IPP identified as Northern Power has a monthly capacity factor of more
    than 1.0. The Commission observes that (i) this power plant has not been fully commissioned,
    and (ii) the capacity factor of this power plant, serving the isolated network in the Jaffna
    peninsula, is likely to be much lower than 1.0. The Commission has assumed that the dispatch is
    correct, and that the filed capacity is incorrect. The relevant PPA has not been submitted for
    review.

(k) Non-dispatchable (must-run) power plants: In the dispatch filed with the Commission, the
    Single Buyer has removed the non-dispatchable (must-run) power plants, all of which are Small
    Power Producers (SPPs). No costs of these have been filed. Commission’s views on these power
    plants are stated in the next section.




Consultation Paper on Setting Tariffs for the period 2011-2015                                     16
3.2.5           NON-DISPATCHABLE RENEWABLE ENERGY POWER PLANTS
    Upon request from the Commission, TL provided the estimated costs of the non-dispatchable power
    plants, which are all Non-conventional Renewable Energy (NCRE) based SPPs. The following
    observations and corrections have been made, before such costs are allowed:

    (a) Avoided cost calculations: Calculation of avoided costs for year 2011, for payments to
        contracts signed before 2007 was not provided. Therefore, the following assumptions were made:
        avoided cost-based tariff for year 2011 would be LKR/kWh 11.00 (wet season), 12.00 (dry
        season).

    (b) Mismatch between avoided costs paid to hydro and biomass, both of which are paid on the same
        basis were observed, and corrected.

    (c) A biomass power plant in the 3-tier tariff, has a tariff of 22 LKR/kWh, and the rate increases
        mid-year. This is not possible based on the tariff methodology for NCRE, and the tariff is
        excessive for this power plant, which is licensed as a power plant of the type “Agricultural and
        Industrial waste”. The tariff was corrected, and no further revisions will be allowed.

    The costs of purchasing non-dispatchable renewable energy power plants, is summarised in Table 6.

                   Table 6- Filed and Allowed Payments to Non-dispatchable NCRE Power Plants
  Type          Pricing basis     Forecast energy       Forecast price    Allowed payments   Payment on      Additional burden on customers
                of agreement      purchased (GWh)        (LKR/kWh)          (LKR million)    avoided costs   (LKR million)   (LKR/kWh of
                                  Filed   Corrected   Filed   Corrected      Corrected       (LKR million)                   end-use sales)
Minihydro Avoided cost            188.0     197.7     11.98    11.50              2,273           2,273                0.0        0.00
                   3-tier           9.6      10.1     14.27    11.77                119             116                2.7        0.00
Biomass         Avoided cost        1.2       1.3     14.00    11.50                 15              15                0.0        0.00
                   3-tier          12.0      12.6     22.00      9.90               125             145              -20.2       -0.00
Wind               3-tier          46.0      48.4     24.73    23.58              1,140             556              584.2        0.12
Total                             256.8     270.0                                 3,672           3,105             566.8        0.12
    Note: The above information is for the six-month period January to June 2011.



    The Single Buyer has not submitted to the Commission, the manner in which the costs of the SPPs
    could be met. Considering the filed budget of LKR 8969 million for year 2011 for the purchase of
    620 GWh (14.46 LKR/kWh), the Commission is of the view that there should be clarity on how these
    costs are to be met. As these power plants are non-dispatchable, the Single Buyer has no option to
    refuse energy from these power plants, but to purchase from them, even when there can be other
    generators which could produce electricity cheaper than 14.46 LKR/kWh.

    As an interim measure, the Commission proposes allowing a levy on the Single Buyer’s energy costs,
    which would be transparently passed-on to end-use customers. This levy would be allowed on the
    basis that the Single Buyer would
        (i)       fully disclose the detailed tariff schedule for payments to each SPP, in conformity with the
                  instructions issued by the Ministry of Power and Energy from time to time, and the
                  announcements made by Sri Lanka Sustainable Energy Authority from time to time, which
                  have already been made available to this Commission
        (ii)      submit the detailed calculation of avoided costs payable to some of the SPPs for year 2011
    and pending a Government policy guideline on
        (iii)     how the costs of SPPs are to be met in the future
        (iv)      any caps on the quantity and price paid to such purchases
        (v)       any caps on what portion of such costs should be passed-on to electricity customers
    The levy on the SB’s pass-through costs allowed for non-dispatchable renewable energy power plants
    will be withdrawn, unless the above conditions are met by the SB and the Government’s Policy
    Guidelines are received before the next SB’s filing, due in May 2011 for the period July – December,
    2011.

    In addition a ‘Green Tariff’ is proposed for industrial consumers who desire to purchase green energy
    for their products, to recover at least part of this additional cost. A premium of Rs. 3.00/ KWh over
    and above their unit rate is proposed.




    Consultation Paper on Setting Tariffs for the period 2011-2015                                                                       17
3.2.6          ALLOWED REVENUES OF THE SINGLE BUYER
The allowed revenues of the Single-buyer (inclusive of the Transmission and BSOB), after the making
the revisions stated in section 3.2.5 are shown in Table 7.




          Table 7- Allowed Revenue of the Single Buyer (incl Transmission and BSOB)
Capacity Charge

Month                             Unit            1               2               3              4               5            6

Capacity Charge
           Generation capacity LKR/MW           948,017        951,673         967,379         980,802         943,882    1,005,529
                 Transmission LKR/MW            272,218        273,215         277,275         277,533         265,322      289,091
           Bulk Supply Service LKR/MW             4,735          4,752           4,823           4,827           4,615        5,028
BST (C)                        LKR/MW        1,224,970      1,229,639       1,249,477       1,263,162       1,213,818    1,299,649

BST (C)
                               LKR/MW        1,246,070
6-Month Weighed average

Energy Charge

Month                             Unit            1               2               3              4               5            6


Interval 1 (day)
    Transmission Loss Factor B1    %            2.67%          2.67%             2.67%          2.67%          2.67%        2.67%
     Generation energy Cost B1 LKR/kWh           7.44           7.12              7.20           6.99           6.52         6.53
BST (E1)                        LKR/kWh          7.64           7.31              7.40           7.18           6.69         6.71

Interval 2 (peak)
    Transmission Loss Factor B2    %            3.41%          3.41%             3.41%          3.41%          3.41%        3.41%
     Generation energy Cost B2 LKR/kWh           9.67           9.25              9.36           9.08           8.47         8.49
BST (E2)                        LKR/kWh         10.01           9.58              9.70           9.41           8.77         8.79

Interval 3 (off-peak)
    Transmission Loss Factor B3    %            1.89%          1.89%             1.89%          1.89%          1.89%        1.89%
     Generation energy Cost B3 LKR/kWh           5.20           4.98              5.04           4.89           4.56         4.57
BST (E3)                        LKR/kWh          5.31           5.08              5.14           4.99           4.65         4.66


                                                                            Renewable
                                             Economic        ST debt
                                                                           energy above     Total BST (E)
                                              dispatch       recovery
                                                                           avoided costs
BST day (E1)
                               LKR/kWh          7.16           0.52              0.11           7.78
6-Month weighed average
BST peak (E2)
                               LKR/kWh          9.37           0.52              0.11           10.00
6-Month weighed average
BST off-peak (E3)
                               LKR/kWh          4.97           0.52              0.11           5.60
6-Month weighed average



Special Levies on BST (included in all intervals above)

Total commitment on ST debts   LKR million     2800.0
for the period
Levy on NCRE purchases in      LKR million      566.0
excess of avoided costs
BST = Bulk Supply Tariff. These refer to the tariff at which electricity will be sold by the TL to DLs, or to any
customers purchasing direct from the TL.
NCRE = Non-conventional Renewable Energy, which are non-dispatchable


     3.2.7          PROVISION FOR THE SETTLEMENT OF SHORT-TERM DEBTS
As explained earlier, CEB Licensees (DL1-4) and TL filed for a recovery of costs to service the short-
term debts, by embedding such costs in overheads. Upon clarification by the Commission, these were
identified and separated out. Table 8 shows the calculated profile of debt service, to settle these
short-term debts, estimated by the Commission based on the CEB licensee responses to clarifications.

                Table 8-Filed Provisions to Settle Short-term Debts of CEB Licensees

                     Year                2010             2011           2012           2013       2014          2015
                   Total debt
                  service (LKR
                                         5,345            5,600          4,055          1,335        885          790
                    million)

Consultation Paper on Setting Tariffs for the period 2011-2015                                                                      18
The Commission observes that
    (i)      information provided is inadequate, whereas, the details of each loan, its repayment
             schedule, interest payments and interest rates, should have been provided for each month
             of the five year Tariff Period.
    (ii)     copies of the relevant loan agreements should be filed with the Commission
    (iii)    a statement on how the CEB Licensees would negotiate with the lenders, to gain advantage
             of the declining interest rates is required, and
    (iv)     any actions that would enable the short-term debts to be converted to long-term debts or
             other financial instruments, to smoothen the impacts on customers, should be provided

To repay these short-terms debts, the Commission proposes to place a special levy on the pass-
through costs of the Single Buyer, which will be transparently passed-on to customers, and included
in the Bulk Supply Tariff and finally, in the end-use customer tariffs. The Commission would establish
regulatory oversight on the short-term debts, and pass-on any changes to the customers, in each six-
monthly revisions of the Bulk Supply Tariffs.

The amount of this levy to be recovered over the period January to June 2011 is proposed to be
LKR 2800 million, with a full claw-back provision for any variations. If the relevant information
described earlier in this section is not provided, the levy would be completely withdrawn in the next
determination of the Single Buyer’s pass-through tariffs due for the period July-December 2011.


  3.3 ANALYSIS OF COSTS OF LICENSEES

Table 9 shows an analysis of the costs of supply, considering the revenue allowances proposed to be
approved by the Commission.

            Table 9- Analysis of Allowed Costs of Transmission and Distribution Services
                                         2011            2012         2013             2014           2015
               Licensee
                                                             Revenue cap (LKR million)
 DL1                                         6,981         7,303          7,623           7,939        8,286
 DL2                                         7,956         8,318          8,706           9,073        9,455
 DL3                                         4,657         4,859          5,073           5,292        5,517
 DL4                                         3,776         3,926          4,056           4,187        4,318
 DL5                                         2,514         2,581          2,663           2,729        2,780
 Distribution Total                         25,883        26,988         28,122          29,220       30,356
 TL                                          7,288         7,288          7,288           7,288        7,288
 Total                                      33,172        34,276         35,411          36,509       37,645
 Sales Forecast (GWh)                        9,667        10,308         10,989          11,713       12,485

                                                           Sales by each Licensee (GWh)
 DL1                                         2,704         2,882           3,071            3,272      3,486
 DL2 (including sales to DL5)                3,193         3,403           3,626            3,863      4,116
 DL3 (including sales to DL5)                2,115         2,253           2,401            2,558      2,726
 DL4 (including sales to DL5)                1,730         1,843           1,964            2,093      2,230
 DL5                                         1,198         1,241           1,284            1,327      1,370
 Distribution Total                          9,667        10,308          10,989           11,713     12,485
 TL                                         10,890        11,546          12,233           12,974     13,780

                                                   Cost of Service (LKR/kWh sold by each licensee)
 DL1                                            2.58         2.53           2.48               2.43     2.38
 DL2 (including sales to DL5)                   2.49         2.44           2.40               2.35     2.30
 DL3 (including sales to DL5)                   2.20         2.16           2.11               2.07     2.02
 DL4 (including sales to DL5)                   2.18         2.13           2.06               2.00     1.94
 DL5                                            2.10         2.08           2.07               2.06     2.03
 Distribution Total                             2.68         2.62           2.56               2.49     2.43
 TL                                             0.67         0.63           0.60               0.56     0.53

 Total T&D cost (LKR/kWh sold)                  3.43         3.33            3.22             3.12      3.02




The Commission observes that with the allowed revenues, the total Sri Lanka transmission and
distribution costs would decrease in real terms over the five-year tariff period 2011-2015. Table 10
describes the structure of costs applicable for the period January-June 2011.




Consultation Paper on Setting Tariffs for the period 2011-2015                                           19
Table 10- Composition of the Costs to end-users (January - June 2011)
           For a period of six months                      Units           Value                 Notes
                                                                                        50% of annual revenue
           Total DL costs                            LKR million           12,942      cap
System                                                                                  50% of annual revenue
 costs     TL                                        LKR million            3,644      cap
           Single Buyer's capacity costs             LKR million           12,551       Allowed cost
           Single Buyers energy costs                LKR million           38,507       Allowed cost
                                                                                       Allowed levy, interim
           Provision for Short-term debts            LKR million             2800      and conditional
Levies
                                                                                        Allowed levy, interim
           NCRE above avoided costs                  LKR million              566      and conditional
           Total                                     LKR million           71,010
           Six months' sales as a share of annual                           49.1%
           Sales for the six-month period            GWh                    4,748
           Average Price to end-user                 LKR/kWh sold           14.95

   Note: For an assessment of direct and indirect Government subsidies not reflected in the above costs, please
   see section 4.

                            Table 11- Analysis of the Cost Break-up of end-users
                                         Cost component             Cost LKR/kWh sold
                               Distribution and Retail                     2.73
                               Transmission and BSOB                       0.77
                               Generation capacity                         2.64
                               Generation energy                           8.11
                               Levy for short-term debts                   0.59
                               Levy for renewable energy                   0.12
                               Total                                      14.95

                             Note: For an assessment of direct and indirect Government subsidies not reflected in
                             the above costs, please, see section 4.



4. GOVERNMENT SUBSIDIES

  4.1 LONG-TERM DEBTS WRITTEN-OFF AND RESCHEDULED

The Commission has undertaken as assessment of the value of debts written-off, and the avoided
payments to the Government to service the debts of on-going investments, including interest during
construction. These estimates are provided in Table 12.

         Table 12- Evaluation of the Government Subsidy owing to Long-term Debt Relief
                             All costs are in LKR million
                             Interest Payment Position (long-term loans)           Year 2011
                             Laxapana                                                     107
                             Mahaweli                                                      74
                             Other Hydro                                                  151
                             Thermal                                                    8,392
                             Sub total (CEB GL)                                         8,724
                             Transmission (wires)                                       3,601
                             CEB DLs                                                    4,529
                             All CEB Licensees                                       16,854

                             Capital Repayments (long-term loans)                  Year 2011
                             Laxapana                                                      69
                             Mahaweli                                                       3
                             Other Hydro                                                  572
                             Thermal                                                    1,997
                             Sub total (CEB GL)                                         2,641
                             Transmission (wires)                                       2,297
                             CEB DLs                                                      862
                             All CEB Licensees                                         5,800
                             CEB Licensee debt service (long-term loans)             22,654




Consultation Paper on Setting Tariffs for the period 2011-2015                                                  20
4.2 CONCESSIONS ON FUEL PRICES

 The Commission has assessed that the following fuels used in both CEB and IPP generating facilities
 are provided at a concessionary price at the time of the filing.
               (i) Fuel oil 180 cSt (1500 s) for CEB and IPPs: price 42.55 LKR/litre
               (ii) Fuel oil 380 cSt (3500 s) for CEB and one IPP: price 40.00 LKR/litre
               (iii) Fuel oil (low sulphur, for West Coast Power Plant): price 52.00 LKR/litre
 Based on the evidence of pricing submitted by the Single Buyer, the Commission is of the view that
 three other fuels used for generation (coal, auto diesel and naphtha) are priced adequately close to
 the international prices, adjusted by the cost of freight and other charges.

 The Commission estimates that the fuel subsidy for the period of six-months over January – June
 2011 to be LKR 8524 million. In the absence of information filed by the Single Buyer or their fuel
 supplier(s), this subsidy is an estimate.

                   Table 13- Composition of Costs including Government Subsidies

                                                                                                   Share of
                                                                              Cost      Share of
                                                                                                    average
                                                                              LKR      each cost
                                                                                                      cost
                 For a period of six months              Units      Value     per      including
                                                                                                   excluding
                                                                              kWh        Govt
                                                                                                      Govt
                                                                              sold     subsidies
                                                                                                   subsidies
                 Allowed total DL costs               LKR million   12,942    2.73      14.2%        18.2%
                 Allowed TL costs                     LKR million    3,644    0.77      4.0%         5.1%
System costs     Single Buyer's allowed capacity
                                                      LKR million   12,551    2.64      13.8%       17.7%
                 costs
                 Single Buyers allowed energy costs   LKR million   38,507    8.11      42.4%       54.2%
                 Allowed provision for Short-term
                                                      LKR million     2800    0.59       3.1%       3.9%
   Levies        debts
                 Allowed NCRE above avoided costs     LKR million      566    0.12       0.6%       0.8%
                 Costs to be recovered through
 Sub total                                            LKR million   71,010   14.95      78.2%      100.0%
                 tariffs
Government       Relief from long-terms debts         LKR million   11,327    2.39      12.5%
 Subsidies       Concession on fuel prices            LKR million    8,524    1.80      9.4%
                 Total                                              90,860   19.14     100.0%
                 Six month sales as a share of
                                                                     49.1%
                 annual sales
                 Sales                                   GWh         4,748
                 Average Cost inclusive of Govt
                                                       LKR/kWh       19.14
                 subsidies

 Note: The period covered is January – June 2011



 The Commission estimates that the actual cost of the electricity industry in year 2011 would be LKR
 19.14 per kWh sold, which has been subsidised by an extent of 21.9% (LKR 4.19 per kWh) by the
 Government through (i) the debt write-off and the moratorium, and (ii) concessionary pricing of fuel
 prevailing as of the filing date by the licensees.


   4.3 PROCEDURE IF SUBSIDIES OR CONCESSIONS ARE
       CHANGED

 If for any reason, the Government subsidies listed above are not received by the Single Buyer in full,
 the ex-post correction provisions in the approved Methodology for Tariffs will be applied and the
 Single Buyer will be compensated accordingly, and any expenses would be passed on to customers,
 as provided in the approved Methodology for Tariffs.

 Similarly, if the Single Buyer receives any direct or indirect subsidies other than those listed above,
 such subsidies would be clawed back and passed-on to customers as a discount, as provided in the
 approved Methodology for Tariffs.




 Consultation Paper on Setting Tariffs for the period 2011-2015                                         21
5. ROAD MAP FOR TARIFF REBALANCING

  5.1 INTRODUCTION

Cost to supply each group of consumers were calculated using a technical loss allocation methodology
and it has been found that end-use customer tariffs at present are not cross-reflective. Certain
classes of customers are subsidised, while others pay a surcharge to finance the cross subsidy. The
electricity sector is considered to need LKR 34,293 million in direct and indirect subsidies. Removal of
cross-subsidies among electricity customers and gross subsidies to the sector, requires a step-by-step
approach, considering its socio-economic implications.

Table 14- Costs of Supply and Subsidies Required in Year 2011 if Present Tariffs Continue

                                                                         Total
                                                          Total     (Subsidy) or
                            Total       Total Cost                                                      Forecast
                                                       revenue        surcharge           Cost of
Customer Category          Sales          (LKR                                                         revenue
                                                         (LKR             on        supply(LKR/kWh)
                          (GWh)         million)                                                      (LKR/kWh)
                                                       million)      customers
                                                                    (LKR million)
Households
0-30                           233          5,518           1,113        (4,405)           23.66            4.77
31-60                          756         15,928           3,695       (12,233)           21.07            4.89
61-90                        1,018         20,093           5,974       (14,119)           19.73            5.87
91-180                       1,254         22,225          14,973        (7,252)           17.72           11.94
181-600                        492          8,346           9,957         1,611            16.98           20.26
>600                           100          1,479           3,561         2,082
Sub Total                    3,853         73,590          39,273       (34,317)           19.10           10.19
Other LV
Religious                       57          1,004             513          (491)           17.65            9.02
General Purpose 1            1,149         15,809          23,943         8,134            13.76           20.83
Industrial                     238          3,171           2,611          (561)           13.32           10.96
Hotel                            1             19              20              1           15.01           15.73
Street Lighting                148          2,292           3,668         1,376            15.43           24.70
Sub Total                    1,594         22,295          30,754         8,460            13.99           19.29
LV BULK                                                                       -
General Purpose 2              875          9,751          18,555         8,803            11.14           21.20
Industrial 2                 1,561         19,899          19,444          (455)           12.75           12.46
Industrial 2 TOU               174          2,159           2,343           184            12.41           13.47
Hotels 2 TOU                     2             26              30              4           11.10           12.60
Hotels 2 (GP)                   73            824           1,169           345            11.21           15.91
Hotels 2 (IP)                   54            656             625           (31)           12.25           11.67
Sub Total                    2,739         33,315          42,165         8,850            12.16           15.39
MEDIUM VOLTAGE                                                                -
General Purpose 3              223          2,263          4,378          2,115            10.13           19.61
Industrial 3                 1,035         10,965         11,661            697            10.59           11.26
Industrial 3 TOU               143          1,376          1,721            345             9.64           12.06
Hotels 3                         8             77             83               6            9.66           10.44
Hotel 3 TOU                     71            629            725             95             8.89           10.24
Sub Total                    1,480         15,310         18,569          3,259            10.34           12.55
Total                        9,666        144,510        130,761        (13,749)           14.95           13.53


The Commission observes that
(i)   based on the review of licensee costs and allowed revenues described in previous sections of this
      consultation document,
(ii) giving due recognition to the Government for the relief from long-term debts and the currently
      applicable concessionary prices on fuel,
(iii) allowing levies to recover short-term debts and excessive payments for renewable energy,
there will be a revenue shortfall of LKR 13,749 million in year 2011, if the present end-use customer
tariffs continue to apply.

The Commission proposes that to cover the revenue shortfall of LKR 13,749 million (LKR 6874 million
for the period January–June 2011), the customer tariffs be restructured with three key objectives:
(i)   To increase the total expected revenue by 10.5%, to enable ALL the licensees to be financially
      independent from any further grants and subsidies by the Government
(ii) To commence a process of tariff rebalancing, which will progressively move the pricing of
      electricity in Sri Lanka to be cost-reflective by year 2015.
(iii) To commence a process of changing customer tariffs in such a manner that in year 2014, CEB

Consultation Paper on Setting Tariffs for the period 2011-2015                                             22
PUCSL Consultation Paper on 2011-2015 Tariffs
PUCSL Consultation Paper on 2011-2015 Tariffs
PUCSL Consultation Paper on 2011-2015 Tariffs
PUCSL Consultation Paper on 2011-2015 Tariffs
PUCSL Consultation Paper on 2011-2015 Tariffs

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PUCSL Consultation Paper on 2011-2015 Tariffs

  • 1. Consultation Paper on Setting Tariffs for the Period 2011-2015 Public Utilities Commission of Sri Lanka Consultation Paper on Setting Tariffs for the period 2011-2015 1
  • 2. Consultation Paper on Setting Tariffs for the Period 2011-2015 TABLE OF CONTENTS 1. PREAMBLE ............................................................................................................................................................... 5 2. INVITATION FOR PUBLIC COMMENTS ......................................................................................................... 6 3. ALLOWED REVENUES FOR LICENSEES ........................................................................................................ 7 3.1 SALES FORECAST AND ALLOWED LOSSES .......................................................................................................... 7 3.1.1 Sales Forecast and Losses filed by Licensees ........................................................................................... 7 3.1.2 Adjusted Sales Forecast and Allowed Losses ........................................................................................... 7 3.2 ALLOWED COSTS OF LICENSEES ...................................................................................................................... 10 3.2.1 Debt Restructuring of CEB Licensees ..................................................................................................... 10 3.2.2 Costs of Distribution Licensees ............................................................................................................... 10 3.2.3 Costs of the Transmission Licensee......................................................................................................... 14 3.2.4 Revenue Requirements of the Single Buyer ............................................................................................. 15 3.2.5 Non-dispatchable Renewable Energy Power Plants .............................................................................. 17 3.2.6 Allowed Revenues of the Single Buyer .................................................................................................... 18 3.2.7 Provision for the Settlement of Short-term Debts ................................................................................... 18 3.3 ANALYSIS OF COSTS OF LICENSEES ................................................................................................................. 19 4. GOVERNMENT SUBSIDIES................................................................................................................................ 20 4.1 LONG-TERM DEBTS WRITTEN-OFF AND RESCHEDULED ................................................................................... 20 4.2 CONCESSIONS ON FUEL PRICES ........................................................................................................................ 21 4.3 PROCEDURE IF SUBSIDIES OR CONCESSIONS ARE CHANGED ........................................................................... 21 5. ROAD MAP FOR TARIFF REBALANCING .................................................................................................... 22 5.1 INTRODUCTION ................................................................................................................................................ 22 5.2 THE ROAD MAP FOR TARIFF REFORMS ............................................................................................................. 22 5.3 TIME INTERVALS PROPOSED FOR TOU TARIFFS .............................................................................................. 23 6. PROPOSED TARIFFS ........................................................................................................................................... 24 6.1 LEVY ON STREET LIGHTING ............................................................................................................................. 24 6.2 PROPOSED TARIFFS FOR 2011 .......................................................................................................................... 25 6.3 FORM OF THE MONTHLY STATEMENT OF ACCOUNT ......................................................................................... 26 7. CONCLUSION ........................................................................................................................................................ 27 Consultation Paper on Setting Tariffs for the period 2011-2015 2
  • 3. LIST OF TALBLES Table 1- Sales Forecasts and Loss Allowances Filed by Distribution Licensees ................................. 7 Table 2- Sales Forecast and Loss Allowances Filed by the Transmission Licensee ............................ 7 Table 3- Allowed Sales, Purchases and Losses ............................................................................ 8 Table 4- Distribution and Retail Revenues Filed and Allowed Revenues .........................................12 Table 5- Transmission and BSOB Revenues Filed and Allowed Revenues .......................................15 Table 6- Filed and Allowed Payments to Non-dispatchable NCRE Power Plants ...............................17 Table 7- Allowed Revenue of the Single Buyer (incl Transmission and BSOB) .................................18 Table 8-Filed Provisions to Settle Short-term Debts of CEB Licensees ...........................................18 Table 9- Analysis of Allowed Costs of Transmission and Distribution Services ................................19 Table 10- Composition of the Costs to end-users (January - June 2011) .......................................20 Table 11- Analysis of the Cost Break-up of end-users .................................................................20 Table 12- Evaluation of the Government Subsidy owing to Long-term Debt Relief ..........................20 Table 13- Composition of Costs including Government Subsidies..................................................21 Table 14- Costs of Supply and Subsidies Required in Year 2011 if Present Tariffs Continue..............22 Table 15- Approved Roadmap for Tariff Rebalancing ...................................................................22 Table 16- Proposed Intervals in the TOU Tariff ...........................................................................23 Table 17- Allowed Energy Sold to Approved Street Lighting to be Recovered through the Levy for year 2011 ....................................................................................................................................24 Table 18- Existing Tariffs and Proposed Tariffs for January-June 2011 ..........................................25 Table 19- Proposed Form of the Monthly Statement of Account (LV Customers) .............................26 Table 20- Proposed Form of the Monthly Statement of Account (LV bulk and MV customers) ...........27 Consultation Paper on Setting Tariffs for the period 2011-2015 3
  • 4. List of Abbreviations BSOB Bulk Supply and Operations Business BST Bulk Supply Tariff CAPEX Capital Expenditure CEB Ceylon Electricity Board DL Distribution Licensee Distribution and Supply Licensee for CEB Distribution DL1 Region 1 Distribution and Supply Licensee for CEB Distribution DL2 Region 2 Distribution and Supply Licensee for CEB Distribution DL3 Region 3 Distribution and Supply Licensee for CEB Distribution DL4 Region 5 DL5 Distribution and Supply Licensee LECO FSA Fuel Supply Agreement Licensee CEB GL CEB Generation GWh Giagawatt hour kVA kilovolt ampere kW kilowatt kWh kilowatt hour LECO Lanka Electricity Company (Pvt) Ltd. LKR Sri Lanka Rupee LV Low Voltage MV Medium Voltage MWh Megawatt hour NCRE Non-Conventional Renewable Energy O&M Operations & Maintenance OPEX Operating Expenditure PPA Power Purchase Agreement SPPs Small Power Producers TL Transmission and BSOB Licensee TOU Time of Use VAT Value Added Tax WIP Work-in-Progress Consultation Paper on Setting Tariffs for the period 2011-2015 4
  • 5. Consultation Paper on Setting Tariffs for the Period 2011-2015 1. PREAMBLE This consultation paper is issued under Section 30 of the Sri Lanka Electricity Act No 20 of 2009 (the “Act”), for the purpose of allowing consumers and other interested parties to participate in setting the tariffs in accordance with the cost-reflective methodology approved by the Commission. In accordance with Section 32(2)(a) of the Act, the Commission, on 26th July 2010, approved a cost- reflective Methodology for Tariffs and subsequently issued the same to the Transmission Licensee and all the Distribution Licensees . The Methodology for Tariffs issued to the Licensees is available as a separate document . The methodology has the following key features: 1 (i) The purchase of generation by the Transmission and Bulk Supply Licensee (the “Single Buyer”) will be passed-through to the Distribution and Supply Licensees, and thereby to the end-use customers. The revision period for such approved generation pass-through costs will be once in six months. (ii) Tariffs chargeable by the Transmission and Bulk Supply Operations Business of the Transmission Licensee will be based on multi-year tariff principles, where the Base Allowed Revenue for the Transmission Licensee will be capped at the same price each year for the entire Tariff Period (“a fixed revenue cap”), subject to (a) allowances when large transmission capital investments are commissioned, allowed as and when such events occur, and (b) annual adjustments to the Base Allowed Revenue on account of inflation and exchange rate variations. (iii) Tariffs chargeable by the Distribution and Supply Licensees for the Distribution and Supply business will be based on multi-year tariff principles, where the Base Allowed Revenue for each Distribution Licensee will be capped but vary from year to year over the Tariff Period (“a variable revenue cap”), subject to annual adjustments to the Base Allowed Revenue on account of inflation and exchange rate variations, and variations of the number of customers and amount of energy sold. (iv) The Commission has determined that (a) the first six-month period for the determination of generation pass-through costs would commence on 1st January 2011, and that (b) the first Tariff Period for the determination of Transmission Licensee’s and Distribution Licensees’ allowed revenues to be five years commencing on 1st January 2011. (v) To reflect the variations in the allowed generation pass-through costs in each six-month interval, and the Transmission and Distribution allowed revenues once in 12-months, the end- use customer tariffs would be changed once in six months. (vi) Owing to the limited information available to the Commission to assess the Licensees’ revenue requirements, the Commission has determined that there will be an extraordinary tariff filing by the Transmission Licensee and Distribution Licensees on or before 30th June 2011, for the remaining period of the first Tariff Period (ie 2012-2015), by which time, certified information including audited statement of accounts for each Licensee should be filed with the Commission (vii) Owing to the requirement to maintain uniform national tariffs to end-use customers, irrespective of varying costs of each Distribution Licensee, the Commission requested each Licensees to file only their revenue requirements. Once the revenue requirements are reviewed and approved, the Commission has used such Allowed Revenues to develop the proposed end-use customer tariffs. The Commission approved and issued the following time table for the setting of tariffs:  Submission of revenue requirements by the Licensees for the first Tariff Period: 9th September 2010 (completed)  Analysis of revenue requirements, clarifications by Licensees and preparation of the Commission’s proposals: 14th October 2010 (completed)  Period allowed for Public Consultations: 24rd November to 08th December 2010  Public hearing: 15th December 2010  Operational date for new tariffs: 1st January 2011 In fulfilling the relevant sections of Condition 32 of the Transmission and the Bulk Supply License No EL/T/09-002 issued to the Ceylon Electricity Board (CEB), the Transmission Licensee (hereinafter referred to as the TL) has submitted the revenue requirements for the period starting January 2011. available upon request to the Commission or it may be downloaded from www.pucsl.gov.lk 1 Consultation Paper on Setting Tariffs for the period 2011-2015 5
  • 6. In fulfilling the relevant section of Condition 31 of Electricity Distribution and Supply Licenses, the five Licensees namely (i) Ceylon Electricity Board in respect of Region 1 holding license number EL/D/09-003 (hereinafter referred to as DL1) (ii) Ceylon Electricity Board in respect of Region 2 holding license number EL/D/09-004 (hereinafter referred to as DL2) (iii) Ceylon Electricity Board in respect of Region 3 holding license number EL/D/09-005 (hereinafter referred to as DL3) (iv) Ceylon Electricity Board in respect of Region 4 holding license number EL/D/09-006 (hereinafter referred to as DL4) (v) Lanka Electricity Company (Private) Limited holding license number EL/D/09-007 (hereinafter referred to as DL5) have submitted their respective revenue requirements for the five year period commencing January 2011. This consultation document is in six parts. The second part presents the key issues on which the Commission invites public comments and the mode in which such comments would be received. The third part presents the Allowed Revenues to each Licensee. The fourth part presents an analysis of Government Subsidies to the sector. The Road Map for Tariff Restructuring and Re-balancing is presented next, to achieve cost-reflective tariffs over 2011-2015. Finally, the sixth part provides the cost of supply of electricity to each customer category, the subsidies and surcharges, and the end-use customer tariffs proposed by the Commission for the first six-month period commencing 1st January 2011. 2. INVITATION FOR PUBLIC COMMENTS The Commission invites public comments on the following specific proposals listed under each part of this consultation document. Allowed Revenues for each Licensee For the Transmission Licensee and for each Distribution Licensee, (i) The sales forecast and allowed losses of each Licensee’s network (2011-2015) (ii) Allowed revenues for each Licensee (2011-2015) (iii) Allowed provision for energy sold for street lighting (2011-2015) For the Transmission Licensee (iv) Allowed costs of purchases from generation (v) Allowed provision for purchases from non-dispatchable non-conventional renewable energy- based generating facilities above the avoided costs of other power plants of the generating system Road Map for Tariff Restructuring and Rebalancing (vi) Tariff restructuring in each year to move the customer tariffs towards cost-reflective tariffs (vii) The time intervals proposed for the implementation of mandatory Time of Use (TOU) tariffs (viii) The target of moving the electricity sector to break-even by year 2014 and to profitability by 2015. Tariffs Payable by Customers from 1st January 2011 (ix) The Tariff Schedule (x) Contents of the monthly statement of account Public comments may be sent by post or delivered by hand to: Public Utilities Commission of Sri Lanka, Level 6, BOC Merchant Tower, No. 28, St. Michael’s Road, Colombo 03. Comments may also be sent on email to: tariff@pucsl.gov.lk Consultation Paper on Setting Tariffs for the period 2011-2015 6
  • 7. 3. ALLOWED REVENUES FOR LICENSEES 3.1 SALES FORECAST AND ALLOWED LOSSES Forecast sales of electricity and the allowed losses in transmission and distribution have an impact on the investments and operating costs of licensees, and on the pass-through costs of electricity generation, all of which will impact the end-use customer tariffs. 3.1.1 SALES FORECAST AND LOSSES FILED BY LICENSEES Sales forecasts, purchases from the Transmission Licensee (TL) and the loss allowances filed by the Distribution Licensees (DLs) are shown in Table 1. Sales to DLs, purchases from generation and loss allowances filed by the TL are shown in Table 2. Table 1- Sales Forecasts and Loss Allowances Filed by Distribution Licensees DL1 DL2 DL3 DL4 DL5 As filed As filed As filed As filed As filed Year Purchases Sales Loss Purchases Sales Loss Purchases Sales Loss Purchases Sales Loss Purchases Sales Loss (GWh) (GWh) (GWh) (GWh) (GWh) (GWh) (GWh) (GWh) (GWh) (GWh) 2009 2,663 2,354 11.6% 3,208 2,734 14.8% 2,033 1,809 11.0% 1,764 1,544 12.5% 1,120 1,030 8.1% 2010 2,849 2,519 11.6% 3,421 2,925 14.5% 2,175 1,936 11.0% 1,850 1,628 12.0% 1,232 1,132 8.1% 2011 3,003 2,673 11.0% 3,670 3,156 14.0% 2,348 2,090 11.0% 1,868 1,644 12.0% 1,276 1,172 8.1% 2012 3,199 2,847 11.0% 3,899 3,361 13.8% 2,501 2,226 11.0% 1,990 1,751 12.0% 1,321 1,214 8.1% 2013 3,406 3,032 11.0% 4,143 3,580 13.6% 2,664 2,371 11.0% 2,119 1,865 12.0% 1,367 1,256 8.1% 2014 3,628 3,229 11.0% 4,402 3,812 13.4% 2,837 2,525 11.0% 2,257 1,986 12.0% 1,413 1,298 8.1% 2015 3,864 3,439 11.0% 4,667 4,060 13.0% 3,021 2,689 11.0% 2,390 2,115 11.5% 1,459 1,341 8.1% Notes: Loss are given as a % of purchases by each licensee Table 2- Sales Forecast and Loss Allowances Filed by the Transmission Licensee Year Sales Input to TL Losses filed forecast filed by TL by TL (as a filed by (GWh) % of input) TL (GWh) 2010 10,347 10,634 2.70% 2011 10,890 11,185 2.64% 2012 11,559 11,917 3.00% 2013 12,266 12,645 3.00% 2014 13,022 13,424 3.00% 2015 13,802 14,229 3.00% 3.1.2 ADJUSTED SALES FORECAST AND ALLOWED LOSSES The following corrections were made to the licensee loss allowances: (a) The Commission reviewed the losses filed for year 2009. The filed sales of CEB DLs was 8441 GWh (including sales to DL5- LECO). On the basis that TL’s losses in year 2009 were 2.7%, the calculated input to the TL’s network would be 9936 GWh. Therefore, the total CEB licensees’ (TL, and DL1, 2, 3 and 4) network loss for 2009 as a share of input to TL would be 15.0%. With the addition of power plant auxiliary power requirements and power plant step-up transformer losses, CEB reported elsewhere, that the total loss was 14.6%, which is significantly lower than the 15.0% transmission and distribution loss implied in the filed losses. This mismatch was corrected by reducing the allowed losses of all CEB DLs for 2009. (b) The Commission observes the even with the above corrections, the total transmission and distribution network loss of Sri Lanka for year 2009 is estimated to have been 14.2%, which fell short of the policy target of 13.5% in 2009 established in the National Energy Policy and Strategies . 2 2 National Energy Policy and Strategies, The Gazette of the Democratic Socialist Republic of Sri Lanka, Extraordinary, No. 1553/10 – TUESDAY, JUNE 10, 2008 Consultation Paper on Setting Tariffs for the period 2011-2015 7
  • 8. (c) The uncorrected losses (as filed) for the total transmission and distribution network in 2015 was 14.4%. The corrected losses indicate a total network loss of 13.3% in 2015. A target of 12% of transmission and distribution losses (as a share of net generation) has been established for year 2016, in the Government’s ten-year plan . Therefore, allowed losses of all distribution licensees 3 were further adjusted downwards, to enable a target transmission and distribution loss of 12.1% to be met by year 2015. (d) The losses of the TL as a share of input to the TL’s network were allowed as filed. The following corrections were made to the licensee sales forecasts: (e) The sales forecast filed by the TL for 2012-2015 did not match with the purchases filed by DL1, 2, 3 and 4, who are direct customers of TL. This mismatch was corrected, considering at this stage, that DLs’ purchase forecasts are correct. (f) The sale growth forecasts for DL1, 2, 3 and 4 for year 2010 were in the range of 5.5% to 7.0%, whereas DL5 forecast a 9.9% growth. Sales by DL1, 2, 3 and 4 were increased to represent a more realistic 7.9% growth for all sales in Sri Lanka in year 2010. (g) DL5 has filed some of the sales for street lighting as losses. Based on the response to a clarification, this was corrected and identified under sales. (h) DL4 has filed a lower sales growth for year 2011 of 1.0%, which was corrected to 5.0%. Accordingly, in setting tariffs, the Commission proposes to establish the allowed forecast and allowed losses as shown in Table 3. Table 3- Allowed Sales, Purchases and Losses DL1 As filed Corrected Year Purchases Sales Sales Loss Purchases Sales Sales Allowed (GWh) (GWh) growth (GWh) (GWh) growth loss 2009 2,663 2,354 11.6% 2,614 2,354 10.0% 2010 2,849 2,519 7.0% 11.6% 2,828 2,547 8.2% 10.0% 2011 3,003 2,673 6.1% 11.0% 2,983 2,704 6.2% 9.3% 2012 3,199 2,847 6.5% 11.0% 3,164 2,882 6.6% 8.9% 2013 3,406 3,032 6.5% 11.0% 3,360 3,071 6.6% 8.6% 2014 3,628 3,229 6.5% 11.0% 3,568 3,272 6.5% 8.3% 2015 3,864 3,439 6.5% 11.0% 3,797 3,486 6.5% 8.2% DL2 As filed Corrected Year Purchases Sales Sales Loss Purchases Sales Sales Allowed (GWh) (GWh) growth (GWh) (GWh) growth loss 2009 3,208 2,734 14.8% 3,149 2,734 13.2% 2010 3,421 2,925 7.0% 14.5% 3,396 2,958 8.2% 12.9% 2011 3,670 3,156 7.9% 14.0% 3,645 3,193 8.0% 12.4% 2012 3,899 3,361 6.5% 13.8% 3,858 3,403 6.6% 11.8% 2013 4,143 3,580 6.5% 13.6% 4,074 3,626 6.6% 11.0% 2014 4,402 3,812 6.5% 13.4% 4,311 3,863 6.5% 10.4% 2015 4,667 4,060 6.5% 13.0% 4,573 4,116 6.5% 10.0% 3 A Ten-year Horizon Development Framework 2006-2016, Department of National Planning, Ministry of Finance and Planning Consultation Paper on Setting Tariffs for the period 2011-2015 8
  • 9. DL3 As filed Corrected Year Purchases Sales Sales Loss Purchases Sales Sales Allowed (GWh) (GWh) growth (GWh) (GWh) growth loss 2009 2,033 1,809 11.0% 1,995 1,809 9.3% 2010 2,175 1,936 7.0% 11.0% 2,159 1,957 8.2% 9.3% 2011 2,348 2,090 8.0% 11.0% 2,332 2,115 8.1% 9.3% 2012 2,501 2,226 6.5% 11.0% 2,474 2,253 6.6% 8.9% 2013 2,664 2,371 6.5% 11.0% 2,627 2,401 6.6% 8.6% 2014 2,837 2,525 6.5% 11.0% 2,790 2,558 6.5% 8.3% 2015 3,021 2,689 6.5% 11.0% 2,969 2,726 6.5% 8.2% DL4 As filed Corrected Year Purchases Sales Sales Loss Purchases Sales Sales Allowed (GWh) (GWh) growth (GWh) (GWh) growth loss 2009 1,764 1,544 12.5% 1,732 1,544 10.9% 2010 1,850 1,628 5.5% 12.0% 1,836 1,646 6.6% 10.4% 2011 1,868 1,644 1.0% 12.0% 1,930 1,730 5.1% 10.4% 2012 1,990 1,751 6.5% 12.0% 2,051 1,843 6.6% 10.1% 2013 2,119 1,865 6.5% 12.0% 2,173 1,964 6.6% 9.6% 2014 2,257 1,986 6.5% 12.0% 2,305 2,093 6.5% 9.2% 2015 2,390 2,115 6.5% 11.5% 2,440 2,230 6.5% 8.6% DL5 As filed Corrected Year Purchases Sales Sales Loss Purchases Sales Sales Allowed (GWh) (GWh) growth (GWh) (GWh) growth loss 2009 1,120 1,030 8.1% 1,120 1,051 6.2% 2010 1,232 1,132 9.9% 8.1% 1,231 1,155 9.9% 6.2% 2011 1,276 1,172 3.6% 8.1% 1,273 1,198 3.7% 5.9% 2012 1,321 1,214 3.6% 8.1% 1,314 1,241 3.6% 5.6% 2013 1,367 1,256 3.5% 8.1% 1,357 1,284 3.5% 5.4% 2014 1,413 1,298 3.3% 8.1% 1,399 1,327 3.3% 5.2% 2015 1,459 1,341 3.3% 8.1% 1,442 1,370 3.3% 5.0% TL As filed Corrected Year Purchases Sales Sales Loss Purchases Sales Sales Allowed (GWh) (GWh) growth (GWh) (GWh) growth loss 2009 9,754 9,491 2.7% 2010 10,347 10,634 2.7% 10,503 10,219 7.7% 2.7% 2011 10,890 11,185 5.2% 2.6% 11,185 10,890 6.6% 2.6% 2012 11,559 11,917 6.5% 3.0% 11,903 11,546 6.0% 3.0% 2013 12,266 12,645 6.1% 3.0% 12,612 12,233 6.0% 3.0% 2014 13,022 13,424 6.2% 3.0% 13,375 12,974 6.1% 3.0% 2015 13,802 14,229 6.0% 3.0% 14,206 13,780 6.2% 3.0% Total TL and all DL networks Policy As filed Corrected target Sales to Sales Input to Sri Sales to Sales Input to Sri for Sri Year End-use growth TL's Lanka End-use growth TL's Lanka Lanka Customers network T&D Customers network T&D T&D (GWh) (GWh) Loss (GWh) (GWh) Loss losses 2009 8,351 8,371 - 9,754 14.2% 13.5% 2010 8,908 6.7% 10,634 16.2% 9,031 7.9% 10,503 14.0% 2011 9,460 6.2% 11,185 15.4% 9,667 7.0% 11,185 13.6% 2012 10,078 6.5% 11,917 15.4% 10,308 6.6% 11,903 13.4% 2013 10,736 6.5% 12,645 15.1% 10,989 6.6% 12,612 12.9% 2014 11,437 6.5% 13,424 14.8% 11,713 6.6% 13,375 12.4% 2015 12,184 6.5% 14,229 14.4% 12,485 6.6% 14,206 12.1% 12.1% 2016 12.0% Consultation Paper on Setting Tariffs for the period 2011-2015 9
  • 10. 3.2 ALLOWED COSTS OF LICENSEES The Commission observes that the present tariff setting is the first such setting of tariffs after the licenses were issued in October 2009. Four of the five licenses for distribution are held by Ceylon Electricity Board (CEB). The Transmission License is also held by CEB. As CEB operated as a single, vertically integrated utility until the licenses were issued, annual accounts of the functional business units that hold each license have not been previously prepared. A condition in the license is the requirement to prepare and submit audited accounts annually to the Commission. Similarly, the capital expenditure program for at least five years ahead is required to be submitted to the Commission for approval. In this Tariff Setting, the Commission intends to waive these two requirements, and has determined that, (a) a capital expenditure program should be filed by each licensee for Commission approval, by March 2011, (b) annual audited accounts of year 2010 should be submitted by each licensee by June 2011, and considering the limitation of information currently available for the current tariff setting that, (c) an extraordinary tariff setting will be conducted in 2011 in which the licensees would file their revenue requirements for the period 2012-2015 for the approval of the Commission. 3.2.1 DEBT RESTRUCTURING OF CEB LICENSEES Prior to commencing the tariff setting and associated procedures, the Commission conducted a detailed assessment of likely costs of each licensee, including the costs of generation, and made such information available to the Ministry of Finance and Planning, and to the Ministry of Power and Energy. The analysis indicated that CEB licensees would continue to make losses if the present Tariff Order of the Commission, issued in April 2009, continues to be applied. In June 2010, the Commission provided several scenarios of reforms to customer tariffs, to enable the licensees to move to profitability over the period 2011-2015. The Commission observed that the costs of generation would continue to increase in real terms until 2013, and would decline thereafter, with the commissioning of stages 2 and 3 of the Puttalam coal-fired power plant and the Trincomalee coal-fired power plant. The Commission thus briefed the Government (i) on the large burden of servicing the debts of DL1, 2, 3, 4 and the TL, and (ii) the need to cushion the costs of the CEB licensees, directly or indirectly, if their impacts on customer prices are to be managed within reasonable limits, particularly over 2011-2013. In assessing the costs of debt, the Commission is guided by the certified minutes of a meeting held at the Ministry of Finance and Planning on August 6, 2010, chaired by Secretary to the Treasury. The minutes have been circulated to all the CEB licensees and the Commission. The minutes state, under item (3) a. “Total outstanding debt stock (of CEB licensees) to the Treasury and (Ceylon Petroleum Corporation) CPC as at 31.12.2009 should be considered as zero. In other words, as at 01.01.2010 CEB has no outstanding debt”. Under the same treasury meeting referred to above, it is noted under item (3) c. “The servicing of debt including repayment of capital and interest for the investment of about US$3bn (made by the government) during the period from 01.01.2010 – 31.12.2013 should be borne by CEB. However, CEB need not bear the cost of interest for the investment made by the government prior to 31.12.2009. Until a decision is taken, for the purpose of the tariff calculation the interest cost should not be considered”. The Commission therefore, requested CEB licensees to take note of the above when filing their revenue requirement for the period 2011-2015. The Government, however, has not provided guidance on restructuring of CEB licensees’ short-term debts. 3.2.2 COSTS OF DISTRIBUTION LICENSEES The five distribution licensees were provided with a template to submit their costs. The template follows the principles stated in the approved Methodology for Tariffs. In addition, the licensees were requested for additional supporting information. Initially, all the templates were corrected for inaccuracies in formulae. Thereafter, supporting information provided by each licensee was evaluated and the required adjustments were made to the costs. The following is a list of such adjustments done. Consultation Paper on Setting Tariffs for the period 2011-2015 10
  • 11. Distribution Licensees (DL1, 2, 3 and 4): (i) Long term debts: These commitments (capital repayments and interest payable thereon, and interest during construction on loans for on-going capital expenditure projects) had been filed by CEB licensees, in spite of the debt restructuring plan stipulated by the Government (see section 3.2.1). These were removed from the filed costs, and the Licensees were requested to provide a schedule of restructured debts that would be required to be serviced from 2014 onwards. This schedule has not been received, and therefore, the present tariff setting has no provision for servicing long-term debts even after the debt moratorium allowed by the Treasury explained in section 3.2.1 ends in 2013. The Commission proposes to consider any such debts filed and associated interest payments, during the extraordinary tariff setting scheduled to commence in June 2011, if the details of such debts are filed. (ii) Short-term debts: Licensees have filed the cost of repayment of short-term debts, as “headquarters overheads”. The Commission observes that such inclusion would cause the distribution licensee costs to be distorted. The Commission proposes to include such debt recovery as a levy under the generation pass-through costs (please see further details in section 3.2.7). (iii) Other revisions: (a) Operating expenditure (OPEX) and capital expenditure (CAPEX) were mixed in certain filings, and these were adjusted accordingly. Similarly, VAT and customs duty components associated with such expenditure were adjusted. (b) The salary increase of 21.6% included in the filing was allowed for year 2012, considering the submission that salaries have not been increased in 2010. Thereafter, the salaries remain constant until 2014. From 2015 onwards, salary increases have been adjusted to be 3.5% in real terms. The same was applied in assessing the costs of salaries at the headquarters of each licensee. (c) Non Salary OPEX was adjusted to increase at the same rate as the customer growth percentage filed by the licensees. (d) The non-salary overhead I (Regional Head Quarters Overhead) costs of licensees have been corrected to remain constant in real terms throughout the tariff period, at the level filed for 2010. (e) Following information obtained from licensees, the non-amortized customer contribution was removed from the asset base and included as a separate line item in the revenue template for calculations (f) The filed CAPEX allowance for new vehicles was decreased by 50% (from 2011 onwards) as an interim measure, pending a comprehensive review during the approval process of the CAPEX program due in March 2011. The forecast depreciation was adjusted accordingly. (g) OPEX of the retail business was adjusted to increase at the same rate as the customer growth percentage (h) Income from sales to street lighting was removed from bad debts. Distribution licensee DL5: (i) Salaries of DL5 (LECO) were allowed a 8.5% real increase in 2011, and thereafter, a 3.5% real increase annually over 2012-2015 was allowed. (j) Non Salary OPEX was adjusted to increase at the same rate as the customer growth percentage filed by the licensees. (k) The non-salary Head Quarters overhead costs have been corrected to remain constant in real terms throughout the tariff period, at the level filed for 2010. (l) Following information obtained from the licensee, the non-amortized customer contribution was removed from the asset base and included as a separate line item in the revenue template for calculations (m) CAPEX allowance for new vehicles have been decreased by 50% as an interim measure, pending a comprehensive review during the approval process of the CAPEX program due in March 2011. The depreciation forecast was adjusted accordingly. (n) OPEX of the retail business was adjusted to increase at the same rate as the customer growth percentage (o) Bad debts were adjusted by taking out the sales to street lighting, as provided by the licensee, and added that component as sales. Consultation Paper on Setting Tariffs for the period 2011-2015 11
  • 12. Filed Revenue Requirements and Allowed Revenues proposed by the Commission are summarised in Table 4. Table 4- Distribution and Retail Revenues Filed and Allowed Revenues As filed by the Licensee Distribution Licensee 1 (DL1) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 8,014.4 8,384.5 8,750.6 9,113.5 9,511.0 Retail Service Allowed Revenue Retail Service Price Cap LKR/customer 428.4 428.4 428.4 428.4 428.4 Total Revenue Summary Distribution LKR million 8,014.4 8,384.5 8,750.6 9,113.5 9,511.0 Retail Service LKR million 550.8 576.4 602.5 626.8 655.2 TOTAL LKR million 8,565.2 8,960.9 9,353.1 9,740.3 10,166.3 Distribution revenue per MWh sold LKR/MWh 2,963.9 2,909.3 2,849.4 2,785.3 2,728.4 Distribution revenue per customer served LKR/customer 6,234.5 6,214.0 6,214.5 6,233.9 6,233.8 Proposed by the Commission Distribution Licensee 1 (DL1) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 6,423.2 6,719.9 7,013.3 7,304.1 7,622.7 Retail Service Allowed Revenue Retail Service Price Cap LKR/customer 433.7 433.7 433.7 433.7 433.7 Total Revenue Summary Distribution LKR million 6,423.2 6,719.9 7,013.3 7,304.1 7,622.7 Retail Service LKR million 557.7 583.3 609.9 634.7 663.6 TOTAL LKR million 6,980.9 7,303.2 7,623.2 7,938.8 8,286.4 Distribution revenue per MWh sold LKR/MWh 2,375.4 2,331.7 2,283.7 2,232.3 2,186.7 Distribution revenue per customer served LKR/customer 4,996.7 4,980.3 4,980.7 4,996.3 4,996.1 All renevues are in constant January 2011 currency As filed by the Licensee Distribution Licensee 2 (DL2) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 8,147.4 8,524.7 8,918.7 9,294.6 9,686.8 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 551.2 551.2 551.2 551.2 551.2 Total Revenue Summary Distribution LKR million 8,147.4 8,524.7 8,918.7 9,294.6 9,686.8 Retail Service LKR million 835.1 870.2 917.0 959.8 1,004.3 TOTAL LKR million 8,982.5 9,394.9 9,835.7 10,254.4 10,691.0 Distribution revenue per MWh sold LKR/MWh 2,551.7 2,505.1 2,459.6 2,406.0 2,353.4 Distribution revenue per customer served LKR/customer 5,377.9 5,359.0 5,339.7 5,350.7 5,362.0 Proposed by the Commission Distribution Licensee 2 (DL2) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 7,124.6 7,454.5 7,799.0 8,127.7 8,470.7 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 544.7 544.7 544.7 544.7 544.7 Total Revenue Summary Distribution LKR million 7,124.6 7,454.5 7,799.0 8,127.7 8,470.7 Retail Service LKR million 831.0 863.6 907.5 945.1 984.3 TOTAL LKR million 7,955.6 8,318.1 8,706.5 9,072.8 9,455.0 Distribution revenue per MWh sold LKR/MWh 2,231.3 2,190.6 2,150.9 2,104.0 2,058.0 Distribution revenue per customer served LKR/customer 4,702.8 4,686.2 4,669.3 4,679.0 4,688.9 All renevues are in constant January 2011 currency Consultation Paper on Setting Tariffs for the period 2011-2015 12
  • 13. As filed by the Licensee Distribution Licensee 3 (DL3) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 5,708.9 5,963.4 6,225.4 6,493.5 6,769.4 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 405.6 405.6 405.6 405.6 405.6 Total Revenue Summary Distribution LKR million 5,708.9 5,963.4 6,225.4 6,493.5 6,769.4 Retail Service LKR million 448.6 464.0 486.0 509.5 533.0 TOTAL LKR million 6,157.5 6,427.4 6,711.4 7,003.0 7,302.4 Distribution revenue per MWh sold LKR/MWh 2,699.3 2,646.9 2,592.8 2,538.5 2,483.3 Distribution revenue per customer served LKR/customer 5,181.1 5,173.1 5,172.1 5,176.0 5,185.6 Proposed by the Commission Distribution Licensee 3 (DL3) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 4,210.5 4,398.2 4,591.4 4,789.2 4,992.7 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 401.4 401.4 401.4 401.4 401.4 Total Revenue Summary Distribution LKR million 4,210.5 4,398.2 4,591.4 4,789.2 4,992.7 Retail Service LKR million 446.3 460.7 481.8 502.8 524.2 TOTAL LKR million 4,656.8 4,858.9 5,073.2 5,292.0 5,516.9 Distribution revenue per MWh sold LKR/MWh 1,990.8 1,952.2 1,912.3 1,872.2 1,831.5 Distribution revenue per customer served LKR/customer 3,821.2 3,815.3 3,814.6 3,817.5 3,824.5 All renevues are in constant January 2011 currency As filed by the Licensee Distribution Licensee 4 (DL4) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 4,985.4 5,159.5 5,336.3 5,514.7 5,693.0 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 477.1 477.1 477.1 477.1 477.1 Total Revenue Summary Distribution LKR million 4,985.4 5,159.5 5,336.3 5,514.7 5,693.0 Retail Service LKR million 359.7 398.7 412.5 425.1 443.9 TOTAL LKR million 5,345.1 5,558.2 5,748.8 5,939.8 6,136.9 Distribution revenue per MWh sold LKR/MWh 2,881.7 2,799.5 2,717.0 2,634.8 2,552.9 Distribution revenue per customer served LKR/customer 6,074.1 6,151.0 6,237.0 6,332.2 6,437.8 Proposed by the Commission Distribution Licensee 4 (DL4) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 3,437.0 3,557.1 3,679.0 3,802.0 3,924.9 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 436.1 436.1 436.1 436.1 436.1 Total Revenue Summary Distribution LKR million 3,437.0 3,557.1 3,679.0 3,802.0 3,924.9 Retail Service LKR million 338.5 368.9 377.5 385.5 393.0 TOTAL LKR million 3,775.6 3,926.0 4,056.5 4,187.4 4,318.0 Distribution revenue per MWh sold LKR/MWh 1,986.7 1,930.1 1,873.2 1,816.5 1,760.1 Distribution revenue per customer served LKR/customer 4,187.7 4,240.6 4,299.9 4,365.6 4,438.4 All renevues are in constant January 2011 currency Consultation Paper on Setting Tariffs for the period 2011-2015 13
  • 14. As filed by the Licensee Distribution Licensee 5 (DL5) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 2,377.7 2,441.7 2,505.3 2,568.5 2,631.3 Retail Service Allowed Revenue Retail Service Price Cap LKR/customer 666.6 666.6 666.6 666.6 666.6 Total Revenue Summary Distribution LKR million 2,377.7 2,441.7 2,505.3 2,568.5 2,631.3 Retail Service LKR million 308.0 325.0 361.0 383.0 393.0 TOTAL LKR million 2,685.7 2,766.7 2,866.3 2,951.5 3,024.3 Distribution revenue per MWh sold LKR/MWh 1,984.7 1,967.5 1,951.2 1,935.6 1,920.7 Distribution revenue per customer served LKR/customer 4,765.6 4,744.8 4,724.4 4,704.5 4,684.9 Proposed by the Commission Distribution Licensee 5 (DL5) Unit 2011 2012 2013 2014 2015 Distribution Allowed Revenue Distribution Variable Revenue Cap LKR million 2,219.0 2,278.7 2,338.1 2,397.1 2,455.7 Retail Service Allowed Revenue Retail Service Price Cap LKR/cust 595.9 595.9 595.9 595.9 595.9 Total Revenue Summary Distribution LKR million 2,219.0 2,278.7 2,338.1 2,397.1 2,455.7 Retail Service LKR million 295.5 302.7 325.0 332.2 324.4 TOTAL LKR million 2,514.4 2,581.4 2,663.0 2,729.3 2,780.1 Distribution revenue per MWh sold LKR/MWh 1,852.2 1,836.2 1,820.9 1,806.4 1,792.5 Distribution revenue per customer served LKR/customer 4,447.5 4,428.1 4,409.0 4,390.4 4,372.2 All renevues are in constant January 2011 currency 3.2.3 COSTS OF THE TRANSMISSION LICENSEE The Transmission Licensee (TL) has two business operations, namely (i) the Transmission Business (ii) the Bulk Supply and Operations Business (BSOB). In addition, the TL is also the Single Buyer, purchasing from all the Generation Licensees (GLs). In this sub section, the Transmission and BSOB businesses are discussed. The single buyer’s business is discussed in the next sub section. Initially, the TL’s template was corrected for inaccuracies in formulae in the base template provided by the Commission. Thereafter, supporting information provided by the TL was evaluated and the required adjustments were made to the costs. The following is a list of such adjustments done. (a) Long term debts: These commitments were removed on the same basis as for DL1, 2, 3 and 4, as previously explained. (b) Short-term debts: These were removed to be included as a levy in the Single Buyer’s pass- through costs, as previously explained. (c) Work-in-Progress: A large Work-in-progress (WIP) for on-going projects was observed. This was allowed, subject to certain projects on which information was not available. Projects that were not part of the transmission or BSOB, were removed. VAT and financial costs were adjusted accordingly. (d) In OPEX, with the absence of detailed information, it was assumed that 50% of filed OPEX would be for salaries, which were allowed to escalate on the basis that a salary increase of 21.6% was allowed for year 2012, considering the submission that salaries have not been increased in 2010. Thereafter, the salaries remain constant until 2014. From 2015 onwards, salary increases have been adjusted to be 3.5% in real terms. The same was applied in assessing the costs of salaries at the headquarters of the licensee. (e)It was assumed that 60% of the OPEX filed for Transmission Overheads were salaries, which were allowed on the same basis as above.(f)CEB Corporate Overheads included a provision for the settlement of short-term loans. This was removed as described earlier. Table 5 shows the filed Revenue Requirements and Allowed Revenues proposed by the Commission. Consultation Paper on Setting Tariffs for the period 2011-2015 14
  • 15. Table 5- Transmission and BSOB Revenues Filed and Allowed Revenues As filed by the Licensee Unit 2011 2012 2013 2014 2015 Transmission Allowed Revenue Transmission Revenue Cap LKR million 9,293.7 9,293.7 9,293.7 9,293.7 9,293.7 Bulk Supply and Operations Business Allowed Revenue BSOB Revenue Cap LKR million 207.0 207.0 207.0 207.0 207.0 Total Revenue Summary Transmission LKR million 9,293.7 9,293.7 9,293.7 9,293.7 9,293.7 BSOB LKR million 207.0 207.0 207.0 207.0 207.0 TOTAL LKR million 9,500.7 9,500.7 9,500.7 9,500.7 9,500.7 Revenue per MWh served LKR/MWh 830.9 779.9 735.0 692.3 653.2 Revenue per kW LKR/kW 4,130.6 3,883.7 3,664.7 3,473.0 3,279.4 Proposed by the Commission Unit 2011 2012 2013 2014 2015 Transmission Allowed Revenue Transmission Revenue Cap LKR million 7,163.7 7,163.7 7,163.7 7,163.7 7,163.7 Bulk Supply and Operations Business Allowed Revenue BSOB Revenue Cap LKR million 124.6 124.6 124.6 124.6 124.6 Total Revenue Summary Transmission LKR million 7,163.7 7,163.7 7,163.7 7,163.7 7,163.7 BSOB LKR million 124.6 124.6 124.6 124.6 124.6 TOTAL LKR million 7,288.3 7,288.3 7,288.3 7,288.3 7,288.3 Revenue per MWh served LKR/MWh 640.5 601.1 566.5 533.6 503.5 Revenue per kW LKR/kW-year 3,183.9 2,993.6 2,824.8 2,677.0 2,527.8 All renevues are in constant January 2011 currency 3.2.4 REVENUE REQUIREMENTS OF THE SINGLE BUYER As stated in the approved Methodology for Tariffs, the Single Buyer costs are filed for a period of six months (January to June). The Commission has the following observations and the corresponding revisions were made to the filed revenues. (a) Power Purchase Agreements (PPAs) between the Transmission Licensee and CEB Generation Licensee (CEB GL): PPAs between TL and CEB GL with respect to each power plant have not been submitted to the Commission for review and approval, as required in the Methodology for Tariffs. The Commission observes that depreciation of full generation assets has been included in the capacity charges of CEB GL’s power plants. As all the long-term debts have been written off or restructured, CEB GL has no debt repayment or interest commitments in year 2011. Hence there is no justification to charge the full cost of depreciation on CEB GL’s power plants on customers. Therefore, the Commission proposes to remove the provision for depreciation included in CEB GL’s power plant capacity charges. Accordingly, a sum of LKR 6681 million estimated to have been filed as depreciation charges for year 2011 was removed from the Single Buyer’s filed generation capacity charges. However, the investments on these power plants may have included a certain amount of CEB’s equity, which has to be returned over a period of time. Based on information available to the Commission, the value of CEB generation assets were estimated to be LKR 267,000 million, on which CEB’s equity was assumed to be 20%. The Government or CEB have not indicated a desire to earn a return on equity on this investment. As a means of providing a return of equity (not return on equity) over a period of 40 years, a sum of 2.5% of the estimated equity was allowed annually. Accordingly, a sum of LKR 1336 million in Consultation Paper on Setting Tariffs for the period 2011-2015 15
  • 16. 2011 was provided for the purpose of return of equity, and added to the Single Buyer’s revenue requirements. The Commission reiterates that this is an interim arrangement, and that the process of filing the PPAs between CEB GLs and TL and approval by the Commission should be completed by 31st December 2010. (b) Fixed O&M costs of CEB Power Plants: CEB thermal power plant capacity charges filed have a fixed, non-fuel energy charge of about LKR 2 per kWh. The Commission observes that this charge is excessive, but has been allowed pending a more comprehensive analysis during the approval of the CEB GL’s PPAs. The non-fuel energy charge filed for gas turbines at Kelanitissa were not allowed, owing to the low dispatch of the plant. (c) Start-stop charges have been filed but estimates for the number of starts-stops have not been filed. (d) Pricing of Petroleum fuels: Fuel Supply Agreements (FSA) were not filed with the Commission. TL provided the most recent invoices or communications with Ceylon Petroleum Corporation stating the prices, and these were used as the basis for fixing the prices of all petroleum fuels used for power generation. (e) Coal pricing: The Fuel Supply Agreement (FSA) has not been submitted to the Commission. Therefore, the pricing was based on an invoice. The Commission observes the following: VAT has been included for coal, whereas for other fuels, VAT is not applicable. Therefore, VAT was removed from coal pricing. A sum of USD 5.65 per tonne has been included as depreciation and overheads within the price calculation for coal, for which the purpose is unclear. This was not allowed. A comprehensive pricing formula including any indices to which the pricing is linked, requires to be filed along with the next Single Buyer’s filing for the period July-December 2011. (f) Hydropower Dispatch: The Single Buyer has not stated whether the filed hydropower dispatch would comply with the probability of occurrence of 70% stated in the Methodology for Tariffs. As the full claw-back provisions are available, the Commission has allowed the filed hydropower dispatch, pending further clarification in the extraordinary filing due in June 2011. (g) Dispatch of the coal-fired power plant: The Commission observes that the coal-fired power plant, operating for the first time in the Tariff Period, has been dispatched only up to an annual capacity factor of 60%. This has been allowed, pending a complete review of the dispatch procedure and limitations before the next filing of the Single Buyer, after the power plant completes its commissioning and reliability testing over the first three months of year 2011. (h) Un-dispatched power plant: The power plant GT07 has not been dispatched at all during the six-month period covered in the revenue filing of the Single Buyer, and the filing states that spares are not available. Capacity charges for this power plant have been filed, but were removed, pending a final decision by TL and submission of the relevant information to the Commission. An ex-post adjustment would be allowed for this power plant’s capacity charges, should the TL dispatch the power plant within the six-month period under consideration, but with prior approval of the relevant PPA by the Commission. (i) IPPs not loaded to the rated plant capacity: Some IPPs are not loaded to the full capacity, stated as the “rated or installed capacity” in the respective PPAs submitted to the Commission. The Commission has allowed this situation, pending a final determination before the next filing by the TL for the Single Buyer’s costs. (j) Northern Power: The IPP identified as Northern Power has a monthly capacity factor of more than 1.0. The Commission observes that (i) this power plant has not been fully commissioned, and (ii) the capacity factor of this power plant, serving the isolated network in the Jaffna peninsula, is likely to be much lower than 1.0. The Commission has assumed that the dispatch is correct, and that the filed capacity is incorrect. The relevant PPA has not been submitted for review. (k) Non-dispatchable (must-run) power plants: In the dispatch filed with the Commission, the Single Buyer has removed the non-dispatchable (must-run) power plants, all of which are Small Power Producers (SPPs). No costs of these have been filed. Commission’s views on these power plants are stated in the next section. Consultation Paper on Setting Tariffs for the period 2011-2015 16
  • 17. 3.2.5 NON-DISPATCHABLE RENEWABLE ENERGY POWER PLANTS Upon request from the Commission, TL provided the estimated costs of the non-dispatchable power plants, which are all Non-conventional Renewable Energy (NCRE) based SPPs. The following observations and corrections have been made, before such costs are allowed: (a) Avoided cost calculations: Calculation of avoided costs for year 2011, for payments to contracts signed before 2007 was not provided. Therefore, the following assumptions were made: avoided cost-based tariff for year 2011 would be LKR/kWh 11.00 (wet season), 12.00 (dry season). (b) Mismatch between avoided costs paid to hydro and biomass, both of which are paid on the same basis were observed, and corrected. (c) A biomass power plant in the 3-tier tariff, has a tariff of 22 LKR/kWh, and the rate increases mid-year. This is not possible based on the tariff methodology for NCRE, and the tariff is excessive for this power plant, which is licensed as a power plant of the type “Agricultural and Industrial waste”. The tariff was corrected, and no further revisions will be allowed. The costs of purchasing non-dispatchable renewable energy power plants, is summarised in Table 6. Table 6- Filed and Allowed Payments to Non-dispatchable NCRE Power Plants Type Pricing basis Forecast energy Forecast price Allowed payments Payment on Additional burden on customers of agreement purchased (GWh) (LKR/kWh) (LKR million) avoided costs (LKR million) (LKR/kWh of Filed Corrected Filed Corrected Corrected (LKR million) end-use sales) Minihydro Avoided cost 188.0 197.7 11.98 11.50 2,273 2,273 0.0 0.00 3-tier 9.6 10.1 14.27 11.77 119 116 2.7 0.00 Biomass Avoided cost 1.2 1.3 14.00 11.50 15 15 0.0 0.00 3-tier 12.0 12.6 22.00 9.90 125 145 -20.2 -0.00 Wind 3-tier 46.0 48.4 24.73 23.58 1,140 556 584.2 0.12 Total 256.8 270.0 3,672 3,105 566.8 0.12 Note: The above information is for the six-month period January to June 2011. The Single Buyer has not submitted to the Commission, the manner in which the costs of the SPPs could be met. Considering the filed budget of LKR 8969 million for year 2011 for the purchase of 620 GWh (14.46 LKR/kWh), the Commission is of the view that there should be clarity on how these costs are to be met. As these power plants are non-dispatchable, the Single Buyer has no option to refuse energy from these power plants, but to purchase from them, even when there can be other generators which could produce electricity cheaper than 14.46 LKR/kWh. As an interim measure, the Commission proposes allowing a levy on the Single Buyer’s energy costs, which would be transparently passed-on to end-use customers. This levy would be allowed on the basis that the Single Buyer would (i) fully disclose the detailed tariff schedule for payments to each SPP, in conformity with the instructions issued by the Ministry of Power and Energy from time to time, and the announcements made by Sri Lanka Sustainable Energy Authority from time to time, which have already been made available to this Commission (ii) submit the detailed calculation of avoided costs payable to some of the SPPs for year 2011 and pending a Government policy guideline on (iii) how the costs of SPPs are to be met in the future (iv) any caps on the quantity and price paid to such purchases (v) any caps on what portion of such costs should be passed-on to electricity customers The levy on the SB’s pass-through costs allowed for non-dispatchable renewable energy power plants will be withdrawn, unless the above conditions are met by the SB and the Government’s Policy Guidelines are received before the next SB’s filing, due in May 2011 for the period July – December, 2011. In addition a ‘Green Tariff’ is proposed for industrial consumers who desire to purchase green energy for their products, to recover at least part of this additional cost. A premium of Rs. 3.00/ KWh over and above their unit rate is proposed. Consultation Paper on Setting Tariffs for the period 2011-2015 17
  • 18. 3.2.6 ALLOWED REVENUES OF THE SINGLE BUYER The allowed revenues of the Single-buyer (inclusive of the Transmission and BSOB), after the making the revisions stated in section 3.2.5 are shown in Table 7. Table 7- Allowed Revenue of the Single Buyer (incl Transmission and BSOB) Capacity Charge Month Unit 1 2 3 4 5 6 Capacity Charge Generation capacity LKR/MW 948,017 951,673 967,379 980,802 943,882 1,005,529 Transmission LKR/MW 272,218 273,215 277,275 277,533 265,322 289,091 Bulk Supply Service LKR/MW 4,735 4,752 4,823 4,827 4,615 5,028 BST (C) LKR/MW 1,224,970 1,229,639 1,249,477 1,263,162 1,213,818 1,299,649 BST (C) LKR/MW 1,246,070 6-Month Weighed average Energy Charge Month Unit 1 2 3 4 5 6 Interval 1 (day) Transmission Loss Factor B1 % 2.67% 2.67% 2.67% 2.67% 2.67% 2.67% Generation energy Cost B1 LKR/kWh 7.44 7.12 7.20 6.99 6.52 6.53 BST (E1) LKR/kWh 7.64 7.31 7.40 7.18 6.69 6.71 Interval 2 (peak) Transmission Loss Factor B2 % 3.41% 3.41% 3.41% 3.41% 3.41% 3.41% Generation energy Cost B2 LKR/kWh 9.67 9.25 9.36 9.08 8.47 8.49 BST (E2) LKR/kWh 10.01 9.58 9.70 9.41 8.77 8.79 Interval 3 (off-peak) Transmission Loss Factor B3 % 1.89% 1.89% 1.89% 1.89% 1.89% 1.89% Generation energy Cost B3 LKR/kWh 5.20 4.98 5.04 4.89 4.56 4.57 BST (E3) LKR/kWh 5.31 5.08 5.14 4.99 4.65 4.66 Renewable Economic ST debt energy above Total BST (E) dispatch recovery avoided costs BST day (E1) LKR/kWh 7.16 0.52 0.11 7.78 6-Month weighed average BST peak (E2) LKR/kWh 9.37 0.52 0.11 10.00 6-Month weighed average BST off-peak (E3) LKR/kWh 4.97 0.52 0.11 5.60 6-Month weighed average Special Levies on BST (included in all intervals above) Total commitment on ST debts LKR million 2800.0 for the period Levy on NCRE purchases in LKR million 566.0 excess of avoided costs BST = Bulk Supply Tariff. These refer to the tariff at which electricity will be sold by the TL to DLs, or to any customers purchasing direct from the TL. NCRE = Non-conventional Renewable Energy, which are non-dispatchable 3.2.7 PROVISION FOR THE SETTLEMENT OF SHORT-TERM DEBTS As explained earlier, CEB Licensees (DL1-4) and TL filed for a recovery of costs to service the short- term debts, by embedding such costs in overheads. Upon clarification by the Commission, these were identified and separated out. Table 8 shows the calculated profile of debt service, to settle these short-term debts, estimated by the Commission based on the CEB licensee responses to clarifications. Table 8-Filed Provisions to Settle Short-term Debts of CEB Licensees Year 2010 2011 2012 2013 2014 2015 Total debt service (LKR 5,345 5,600 4,055 1,335 885 790 million) Consultation Paper on Setting Tariffs for the period 2011-2015 18
  • 19. The Commission observes that (i) information provided is inadequate, whereas, the details of each loan, its repayment schedule, interest payments and interest rates, should have been provided for each month of the five year Tariff Period. (ii) copies of the relevant loan agreements should be filed with the Commission (iii) a statement on how the CEB Licensees would negotiate with the lenders, to gain advantage of the declining interest rates is required, and (iv) any actions that would enable the short-term debts to be converted to long-term debts or other financial instruments, to smoothen the impacts on customers, should be provided To repay these short-terms debts, the Commission proposes to place a special levy on the pass- through costs of the Single Buyer, which will be transparently passed-on to customers, and included in the Bulk Supply Tariff and finally, in the end-use customer tariffs. The Commission would establish regulatory oversight on the short-term debts, and pass-on any changes to the customers, in each six- monthly revisions of the Bulk Supply Tariffs. The amount of this levy to be recovered over the period January to June 2011 is proposed to be LKR 2800 million, with a full claw-back provision for any variations. If the relevant information described earlier in this section is not provided, the levy would be completely withdrawn in the next determination of the Single Buyer’s pass-through tariffs due for the period July-December 2011. 3.3 ANALYSIS OF COSTS OF LICENSEES Table 9 shows an analysis of the costs of supply, considering the revenue allowances proposed to be approved by the Commission. Table 9- Analysis of Allowed Costs of Transmission and Distribution Services 2011 2012 2013 2014 2015 Licensee Revenue cap (LKR million) DL1 6,981 7,303 7,623 7,939 8,286 DL2 7,956 8,318 8,706 9,073 9,455 DL3 4,657 4,859 5,073 5,292 5,517 DL4 3,776 3,926 4,056 4,187 4,318 DL5 2,514 2,581 2,663 2,729 2,780 Distribution Total 25,883 26,988 28,122 29,220 30,356 TL 7,288 7,288 7,288 7,288 7,288 Total 33,172 34,276 35,411 36,509 37,645 Sales Forecast (GWh) 9,667 10,308 10,989 11,713 12,485 Sales by each Licensee (GWh) DL1 2,704 2,882 3,071 3,272 3,486 DL2 (including sales to DL5) 3,193 3,403 3,626 3,863 4,116 DL3 (including sales to DL5) 2,115 2,253 2,401 2,558 2,726 DL4 (including sales to DL5) 1,730 1,843 1,964 2,093 2,230 DL5 1,198 1,241 1,284 1,327 1,370 Distribution Total 9,667 10,308 10,989 11,713 12,485 TL 10,890 11,546 12,233 12,974 13,780 Cost of Service (LKR/kWh sold by each licensee) DL1 2.58 2.53 2.48 2.43 2.38 DL2 (including sales to DL5) 2.49 2.44 2.40 2.35 2.30 DL3 (including sales to DL5) 2.20 2.16 2.11 2.07 2.02 DL4 (including sales to DL5) 2.18 2.13 2.06 2.00 1.94 DL5 2.10 2.08 2.07 2.06 2.03 Distribution Total 2.68 2.62 2.56 2.49 2.43 TL 0.67 0.63 0.60 0.56 0.53 Total T&D cost (LKR/kWh sold) 3.43 3.33 3.22 3.12 3.02 The Commission observes that with the allowed revenues, the total Sri Lanka transmission and distribution costs would decrease in real terms over the five-year tariff period 2011-2015. Table 10 describes the structure of costs applicable for the period January-June 2011. Consultation Paper on Setting Tariffs for the period 2011-2015 19
  • 20. Table 10- Composition of the Costs to end-users (January - June 2011) For a period of six months Units Value Notes 50% of annual revenue Total DL costs LKR million 12,942 cap System 50% of annual revenue costs TL LKR million 3,644 cap Single Buyer's capacity costs LKR million 12,551 Allowed cost Single Buyers energy costs LKR million 38,507 Allowed cost Allowed levy, interim Provision for Short-term debts LKR million 2800 and conditional Levies Allowed levy, interim NCRE above avoided costs LKR million 566 and conditional Total LKR million 71,010 Six months' sales as a share of annual 49.1% Sales for the six-month period GWh 4,748 Average Price to end-user LKR/kWh sold 14.95 Note: For an assessment of direct and indirect Government subsidies not reflected in the above costs, please see section 4. Table 11- Analysis of the Cost Break-up of end-users Cost component Cost LKR/kWh sold Distribution and Retail 2.73 Transmission and BSOB 0.77 Generation capacity 2.64 Generation energy 8.11 Levy for short-term debts 0.59 Levy for renewable energy 0.12 Total 14.95 Note: For an assessment of direct and indirect Government subsidies not reflected in the above costs, please, see section 4. 4. GOVERNMENT SUBSIDIES 4.1 LONG-TERM DEBTS WRITTEN-OFF AND RESCHEDULED The Commission has undertaken as assessment of the value of debts written-off, and the avoided payments to the Government to service the debts of on-going investments, including interest during construction. These estimates are provided in Table 12. Table 12- Evaluation of the Government Subsidy owing to Long-term Debt Relief All costs are in LKR million Interest Payment Position (long-term loans) Year 2011 Laxapana 107 Mahaweli 74 Other Hydro 151 Thermal 8,392 Sub total (CEB GL) 8,724 Transmission (wires) 3,601 CEB DLs 4,529 All CEB Licensees 16,854 Capital Repayments (long-term loans) Year 2011 Laxapana 69 Mahaweli 3 Other Hydro 572 Thermal 1,997 Sub total (CEB GL) 2,641 Transmission (wires) 2,297 CEB DLs 862 All CEB Licensees 5,800 CEB Licensee debt service (long-term loans) 22,654 Consultation Paper on Setting Tariffs for the period 2011-2015 20
  • 21. 4.2 CONCESSIONS ON FUEL PRICES The Commission has assessed that the following fuels used in both CEB and IPP generating facilities are provided at a concessionary price at the time of the filing. (i) Fuel oil 180 cSt (1500 s) for CEB and IPPs: price 42.55 LKR/litre (ii) Fuel oil 380 cSt (3500 s) for CEB and one IPP: price 40.00 LKR/litre (iii) Fuel oil (low sulphur, for West Coast Power Plant): price 52.00 LKR/litre Based on the evidence of pricing submitted by the Single Buyer, the Commission is of the view that three other fuels used for generation (coal, auto diesel and naphtha) are priced adequately close to the international prices, adjusted by the cost of freight and other charges. The Commission estimates that the fuel subsidy for the period of six-months over January – June 2011 to be LKR 8524 million. In the absence of information filed by the Single Buyer or their fuel supplier(s), this subsidy is an estimate. Table 13- Composition of Costs including Government Subsidies Share of Cost Share of average LKR each cost cost For a period of six months Units Value per including excluding kWh Govt Govt sold subsidies subsidies Allowed total DL costs LKR million 12,942 2.73 14.2% 18.2% Allowed TL costs LKR million 3,644 0.77 4.0% 5.1% System costs Single Buyer's allowed capacity LKR million 12,551 2.64 13.8% 17.7% costs Single Buyers allowed energy costs LKR million 38,507 8.11 42.4% 54.2% Allowed provision for Short-term LKR million 2800 0.59 3.1% 3.9% Levies debts Allowed NCRE above avoided costs LKR million 566 0.12 0.6% 0.8% Costs to be recovered through Sub total LKR million 71,010 14.95 78.2% 100.0% tariffs Government Relief from long-terms debts LKR million 11,327 2.39 12.5% Subsidies Concession on fuel prices LKR million 8,524 1.80 9.4% Total 90,860 19.14 100.0% Six month sales as a share of 49.1% annual sales Sales GWh 4,748 Average Cost inclusive of Govt LKR/kWh 19.14 subsidies Note: The period covered is January – June 2011 The Commission estimates that the actual cost of the electricity industry in year 2011 would be LKR 19.14 per kWh sold, which has been subsidised by an extent of 21.9% (LKR 4.19 per kWh) by the Government through (i) the debt write-off and the moratorium, and (ii) concessionary pricing of fuel prevailing as of the filing date by the licensees. 4.3 PROCEDURE IF SUBSIDIES OR CONCESSIONS ARE CHANGED If for any reason, the Government subsidies listed above are not received by the Single Buyer in full, the ex-post correction provisions in the approved Methodology for Tariffs will be applied and the Single Buyer will be compensated accordingly, and any expenses would be passed on to customers, as provided in the approved Methodology for Tariffs. Similarly, if the Single Buyer receives any direct or indirect subsidies other than those listed above, such subsidies would be clawed back and passed-on to customers as a discount, as provided in the approved Methodology for Tariffs. Consultation Paper on Setting Tariffs for the period 2011-2015 21
  • 22. 5. ROAD MAP FOR TARIFF REBALANCING 5.1 INTRODUCTION Cost to supply each group of consumers were calculated using a technical loss allocation methodology and it has been found that end-use customer tariffs at present are not cross-reflective. Certain classes of customers are subsidised, while others pay a surcharge to finance the cross subsidy. The electricity sector is considered to need LKR 34,293 million in direct and indirect subsidies. Removal of cross-subsidies among electricity customers and gross subsidies to the sector, requires a step-by-step approach, considering its socio-economic implications. Table 14- Costs of Supply and Subsidies Required in Year 2011 if Present Tariffs Continue Total Total (Subsidy) or Total Total Cost Forecast revenue surcharge Cost of Customer Category Sales (LKR revenue (LKR on supply(LKR/kWh) (GWh) million) (LKR/kWh) million) customers (LKR million) Households 0-30 233 5,518 1,113 (4,405) 23.66 4.77 31-60 756 15,928 3,695 (12,233) 21.07 4.89 61-90 1,018 20,093 5,974 (14,119) 19.73 5.87 91-180 1,254 22,225 14,973 (7,252) 17.72 11.94 181-600 492 8,346 9,957 1,611 16.98 20.26 >600 100 1,479 3,561 2,082 Sub Total 3,853 73,590 39,273 (34,317) 19.10 10.19 Other LV Religious 57 1,004 513 (491) 17.65 9.02 General Purpose 1 1,149 15,809 23,943 8,134 13.76 20.83 Industrial 238 3,171 2,611 (561) 13.32 10.96 Hotel 1 19 20 1 15.01 15.73 Street Lighting 148 2,292 3,668 1,376 15.43 24.70 Sub Total 1,594 22,295 30,754 8,460 13.99 19.29 LV BULK - General Purpose 2 875 9,751 18,555 8,803 11.14 21.20 Industrial 2 1,561 19,899 19,444 (455) 12.75 12.46 Industrial 2 TOU 174 2,159 2,343 184 12.41 13.47 Hotels 2 TOU 2 26 30 4 11.10 12.60 Hotels 2 (GP) 73 824 1,169 345 11.21 15.91 Hotels 2 (IP) 54 656 625 (31) 12.25 11.67 Sub Total 2,739 33,315 42,165 8,850 12.16 15.39 MEDIUM VOLTAGE - General Purpose 3 223 2,263 4,378 2,115 10.13 19.61 Industrial 3 1,035 10,965 11,661 697 10.59 11.26 Industrial 3 TOU 143 1,376 1,721 345 9.64 12.06 Hotels 3 8 77 83 6 9.66 10.44 Hotel 3 TOU 71 629 725 95 8.89 10.24 Sub Total 1,480 15,310 18,569 3,259 10.34 12.55 Total 9,666 144,510 130,761 (13,749) 14.95 13.53 The Commission observes that (i) based on the review of licensee costs and allowed revenues described in previous sections of this consultation document, (ii) giving due recognition to the Government for the relief from long-term debts and the currently applicable concessionary prices on fuel, (iii) allowing levies to recover short-term debts and excessive payments for renewable energy, there will be a revenue shortfall of LKR 13,749 million in year 2011, if the present end-use customer tariffs continue to apply. The Commission proposes that to cover the revenue shortfall of LKR 13,749 million (LKR 6874 million for the period January–June 2011), the customer tariffs be restructured with three key objectives: (i) To increase the total expected revenue by 10.5%, to enable ALL the licensees to be financially independent from any further grants and subsidies by the Government (ii) To commence a process of tariff rebalancing, which will progressively move the pricing of electricity in Sri Lanka to be cost-reflective by year 2015. (iii) To commence a process of changing customer tariffs in such a manner that in year 2014, CEB Consultation Paper on Setting Tariffs for the period 2011-2015 22