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W16385

RAJGHAT POWER HOUSE: THE ECONOMY OR THE ENVIRONMENT1

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Veena Keshav Pailwar wrote this case solely to provide material for class discussion. The author does not intend to illustrate either
effective or ineffective handling of a managerial situation. The author may have disguised certain names and other identifying
information to protect confidentiality.

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This publication may not be transmitted, photocopied, digitized, or otherwise reproduced in any form or by any means without the
permission of the copyright holder. Reproduction of this material is not covered under authorization by any reproduction rights
organization. To order copies or request permission to reproduce materials, contact Ivey Publishing, Ivey Business School, Western
University, London, Ontario, Canada, N6G 0N1; (t) 519.661.3908; (e) cases@ivey.ca; www.iveycases.com.

Copyright © 2016, Richard Ivey School of Business Foundation Version: 2016-06-28

In response to a March 2015 recommendation by several industry participants at a government-sponsored


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power forum, Delhi’s aging and inefficient Rajghat Power House (RPH) was scheduled to close its doors.
The plant had reached the end of its 25-year useful life, and its outdated equipment spewed toxins into
Delhi’s air and water on a daily basis. With the arrival of the recommended date for the plant’s closure—
October 2015—Delhi’s government officials faced a difficult decision. Should they ignore the
environmental degradation to achieve a high growth rate in the short term, or should they protect the
environment to achieve a sustainable growth rate in the long term?
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THE DILEMMA

The government of Delhi had organized a special forum to assess the demand-supply situation for power
in the city and to carve out a timeline for closing Delhi’s ailing power plants. The forum, which consisted
of State Load Dispatch Centre Delhi, Delhi Transco Limited (DTL), and power distribution companies in
Delhi—Tata Power Delhi Distribution Limited (TPDDL), BSES Yamuna Power Limited (BYPL), BSES
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Rajdhani Power Limited (BRPL), and New Delhi Municipal Council (NDMC)—had given its
recommendation in March 2015.2 Besides other suggestions, the forum had recommended the immediate
suspension of operations of the RPH and its permanent closure in October 2015.3
The public expressed some apprehensions about the RPH closure announcement. In the past, the
government had made similar closure announcements, but it had never followed through on them. The plant
remained functional and generated electricity to meet the ever-growing demand for electricity from
consumers and business units in Delhi (see Exhibit 1). But the planning board’s forecast had suggested a
further increase in the demand in the period ahead (Exhibit 2), 4 and the public feared that if the government
Do

1
This case has been written on the basis of published sources only. Consequently, the interpretation and perspectives
presented in this case are not necessarily those of Rajghat Power House or any of its employees.
2
Sweta Goswami, “Powered-Up App Flips the Switch on Power Grid,” The Pioneer, April 4, 2015, accessed January 13,
2015, www.dailypioneer.com/print.php?printFOR=storydetail&story_url_key=powered-up-aap-flips-the-switch-on-power-
grid&section_url_key=city.
3
Ibid.
4
National Capital Region Planning Board, “Power,” Regional Plan 2021, 73–80, accessed October 1, 2015,
http://ncrpb.nic.in/pdf_files/Regional%20Plan%202021%20chapter/11_CH07%20power.pdf.

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closed the RPH plant in October as planned, the capital city would face significant losses in business and
economic activities. On the other hand, running the plant was undermining the quality of life in the city and
threatening the health of its residents.

Environmental Concerns

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As a coal-based power plant with an installed capacity of 135 megawatts (MW) located in the heart India’s
capital city of Delhi, the RPH had been under consideration for closure for many years. Like any other coal-
fired power plant, the RPH contributed to the air pollution problem in Delhi, which was already considered
to be a highly polluted city by world standards.5 In addition to polluting the air, on an annual basis, the plant
dumped 5.5 tonnes of arsenic into the Yamuna River,6 which provided approximately 70 per cent of Delhi’s
water supply.7 Prolonged exposure to air pollution was considered a major cause of respiratory illnesses,
such as chronic bronchitis and upper and lower respiratory tract infections; exposure to arsenic was

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considered a major cause of cancer and heart ailments.

The government had proposed a shutdown of the plant two times previously. The first was during the
Commonwealth Games in 2010, when efforts were being made to reduce pollution in the city, but in the
end, the RPH had to be kept running to provide power to the adjacent Indira Gandhi Indoor Stadium, which
was one of the venues for the games. Subsequently, on efficiency and environmental grounds, in 2011, the
government had given its approval for the RPH’s permanent closure by 2013,8 the time by which the
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Bawana Power Plant, a large gas-based power plant with an installed capacity of 1,500 MW, would be
functioning at its full capacity.

RAJGHAT POWER HOUSE: BACKGROUND

Set up in 1989–90, the RPH was one of six thermal power plants that operated in Delhi (see Exhibit 3). It
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was operated by Indraprashta Power Generation Company Limited (IPGCL), which was wholly owned by
the Delhi government. The plant was situated along the Yamuna River, and it supplied power to the Old
Delhi area of Chandni Chowk and Ballimaran and to two busy medical facilities, the Lok Nayak Jai Prakash
Narayan Hospital and the Govind Ballabh Pant Hospital.

The RPH possessed a total installed capacity of 135 MW, with two units of 67.5 MW each, but the plant
operated much below its capacity. In some months, the station did not generate any electricity. To keep the
station functional, some amount of electricity was consumed by the plant itself, which resulted in a negative
No

net generation of electricity (see Exhibit 3).

As a very old coal-fired plant, the RPH ran on obsolete technology. It burned domestic coal that had high
ash content and low calorific value, which not only reduced the plant’s efficiency but also, as mentioned,
contributed to Delhi’s air and water pollution. Not only did the RPH operate well below its installed
capacity, but it also fell below the efficiency parameters set out by the Delhi Electricity Regulatory
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5
“Delhi Most Polluted City in the World: WHO,” The Indian Express, May 7, 2014, accessed March 18, 2016,
http://indianexpress.com/article/cities/delhi/delhi-most-polluted-city-in-the-world-who.
6
Arunabh Saikia, “The Mystery of the ‘Non-Functional’ Power Plant in the Heart of Delhi,” newslaundry.com, March 10, 2015,
accessed September 18, 2015, www.newslaundry.com/2015/03/10/the-mystery-of-the-non-functional-power-plant-in-the-
heart-of-delhi.
7
“River Yamuna,” rainwaterharvesting.org, accessed September 18, 2015, www.rainwaterharvesting.org/crisis/river-
yamuna.htm.
8
Neha Lalchandani, “Rajghat Power Unit to Stay for a Year,” The Times of India, November 11, 2012, accessed September
28, 2015, http://timesofindia.indiatimes.com/city/delhi/Rajghat-power-unit-to-stay-for-a-year/articleshow/17175578.cms.

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Authority (DERC) (see Exhibit 4). As a result, the facility generated electricity at a much higher cost
compared to those power plants in other states that also supplied electricity to Delhi (see Exhibits 5 and 6).

The RPH had completed its useful life of 25 years in May 2015; however, by that time, its accumulated
depreciation was only 69 per cent, which was far below the expected norm of 90 per cent of book value at
the end of the useful life of a thermal power plant.9 In anticipation of the plant’s eventual closure, which

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remained uncertain, IPGCL stopped performing any major repair and maintenance activity in the facility,
although the uncertainty about the closure date forced IPGCL to at least keep the RPH machinery
operational. IPGCL was required to spend on the RPH’s need-based maintenance so that the plant remained
available for power generation, especially during the peak demand season. IPGCL spent ₹262.4 million10
on such need-based repairs and maintenance at the RPH in 2014–15,11 and these expenses were expected
to rise even further to ₹283.1 million in 2015–16.12

In addition to the expense of maintaining the outdated equipment at the RPH, both the units in the station

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were giving off harmful gases, which were assessed as being above the particulate matter emission norm
of 150 milligrams per cubic nanometre most of the time. To control the harmful emissions from the station,
in April 2014, the Delhi Pollution Committee directed the RPH to reduce its emission of particulate matter.13
In order for the plant to comply with this directive, several new machine purchases (i.e., capital assets) were
required, such as a new boiler, a new turbine, and an online pollution control system. The expenses on such
assets were estimated to be ₹8.775 million for 2015–16. Along with this expense, IPGCL had budgeted an
additional ₹61.278 million for 2016–17 to purchase minor assets of a capital nature for renovation and
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modernization so that the RPH could operate smoothly.

To keep the RPH functional, in addition to machinery upkeep, IPGCL had to spend on the staff deployed
at the facility. The RPH had total staff strength of around 300 employees, and the services of these
employees were governed by the various Fundamental Rules and Supplementary Rules (FRSR) that were
applicable to government employees. IPGCL was mandated to follow the salary structure as per the FRSR
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and, thus, to adjust its staff salaries at par with the increases in the pay and allowances of the government
employees. In the past few years, due to high inflation, the salaries of these employees had increased in the
range of 14 per cent to 18 per cent,14 leading to a substantial increase in the operational costs of the RPH.
All these factors were estimated to increase the facility’s total operating and maintenance expenses from
₹762.1 million in 2014–15 to ₹827 million in 2015–16 (see Exhibit 7). The total expenditure on regular
upkeep amounted to ₹457.8 million annually.15

On the one hand, the cost of power generation at the RPH was increasing, while on the other hand, demand
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for the power it generated was declining. The power distribution companies had a 25-year-long power
purchase agreement with the RPH, and this agreement expired in May 2015. Given the high cost of power
from that station, the distribution companies lacked motivation to renew the agreement.

9
Indraprastha Power Generation Company Ltd., Tariff Petition, accessed September 29, 2015, www.ipgcl-
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ppcl.gov.in/documents/2015_03_16_Petition_IPGCL.pdf.
10
₹ = INR = Indian rupee; all currency amounts are in ₹ unless otherwise specified; ₹1 = US$0.015 on January 21, 2016.
11
Indraprastha Power Generation Company Ltd., op. cit.
12
Ibid.
13
Ibid.
14
Ibid.
15
Sweta Goswami, “Rajghat Power House Will Be Shut, but Will Take Time, Says Minister,” The Hindu, November 21, 2015,
accessed January 8, 2016, www.thehindu.com/news/national/other-states/rajghat-power-house-will-be-shut-but-will-take-
time-says-minister/article7901924.ece.

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DELHI POWER SUPPLY POSITION

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Besides the RPH, there were five more major power-generating stations in Delhi: Gas Turbine (GT), Pragati
Power Corporation Ltd. (PPCL), Badarpur Thermal Power Station (BTPS), Rithala Gas Turbine, and the
Bawana Power Plant. These power stations used either coal or gas for generating power. A small amount
of power was also generated by Timarpur Okhla Waste Management Company Limited (TOWMCL),

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which generated power by utilizing municipal solid waste.

Besides the power-generating companies, transmission and power distribution companies made up another
part of the power supply chain. DTL transmitted the power generated by the plants to various distribution
companies in the city. The distribution of power in Delhi was handled by three private companies—BRPL,
BYPL, and TPDDL—and by two government companies—NDMC and Military Engineering Services
(MES). Two of the distribution companies, BRPL and BYPL, were controlled by Reliance Infrastructure,
and this pair dominated the market for power distribution in the eastern, western, and southern parts of the

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capital. TPDDL was controlled by Tata Power Corporation, which distributed power to the north and
northwest parts of Delhi. NDMC and MES distributed power to the sensitive parts of the capital, which
included various government buildings. After thorough scrutiny of the proposals submitted by the power
distribution companies, the DERC fixed the power tariff rates for the distribution companies as well as for
end consumers.

Of the six thermal power plants, the RPH, GT, and BTPS were very old, and all three had reached their
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useful life of 25 years. The other three power plants were gas-based and were relatively young, but frequent
gas supply shortages affected their performance and increased their cost of power generation. For example,
the Bawana Power Plant, the youngest of the plants in Delhi, with an installed capacity of 1,500 MW, could
operate with a plant load factor of just 18.16 per cent in June 2015. Because of the capacity underutilization
at the Bawana Plant, its average cost of production remained almost the same as that of the RPH.

The total power generated by Delhi’s power plants was insufficient to keep up with the overall demand for
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power in the city. This situation was due not only to insufficient installed capacity within Delhi but also to
the underutilization of the existing capacity, which was reflected in the low plant load factor. The power
plants were unable to achieve high plant load factors mainly due to the lack of timely availability of coal to
the coal-fired plants and gas to the gas-based plants. At other times, these fuels were available in sufficient
quantities, but the distribution companies preferred load-shedding over buying more power from the power-
generating units, in spite of end-consumers’ large demand for power. The distribution companies frequently
opted for load-shedding because power tariff rates, which were fixed by the DERC, were at times not high
No

enough to recover the cost of production.

As a result of these shortages, Delhi depended on other states and regions of the country to meet its ever-
growing demand for power. For the distribution companies, the cost of power procured from the units
located in Delhi was much higher than that procured from the units located outside Delhi, and this gap had
increased substantially over the years. Highlighting the growing disparity between the two sources, the
power distribution companies pointed out that “the gap in the costing of Delhi station as compared to others
increased from 7 per cent in FY (Fiscal Year) 2010–11 to 53 per cent in FY 2014–15.”16
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Although it was much cheaper to purchase power from production units located outside the state, the
capacity of the transmission lines restricted procurement from these units and forced the distribution
companies to buy power from in-state power-generating units. These constraints kept the overall power-

16
Delhi Electricity Regulatory Commission, Order on True Up for FY 2012–13, FY 2013–14 Aggregate Revenue Requirement
and Generation Tariff for FY 2015–16 for Indraprastha Power Generation Company Limited (IPGCL) (September 2015),
accessed May 25, 2016, www.derc.gov.in/ordersPetitions/orders/Tariff/Tariff%20Order/2015-16/IPGCL.pdf.

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procurement costs much higher for power distribution companies in Delhi. Power distribution companies
pointed out that if the cost of power procurement from plants located in Delhi and those located outside
Delhi had been the same, the distributors would have achieved savings of approximately ₹16 billion
between 2010–11 and 2014–15.17

GOVERNMENT’S STAND

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In spite of its small size and advanced age, the RPH occupied a critical position in supplying power within
the city of Delhi. The plant was of the utmost importance in summer, when the peak demand rose
substantially. If the RPH and other ailing plants were shut down, the capital city’s dependence on other
states for its power supply would increase even further. There was another side to this problem as well in
that the existing distribution network was very weak and often experienced difficulty in bearing the extra
load of distributing electricity from other states.

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Lamenting the poor health of the distribution network, Power Minister Satyendra Jain stated: “The Rajghat
and Badarpur stations are old but give around 720 MW in total, which cannot be compromised, especially
in summers. So we have put the issue of shutting them down on hold for two years. We have to strengthen
the distribution system within two years so that the extra load can be taken by the alternate lines.”18

Besides the environmental problems of air and water pollution and the inability to efficiently transmit
power, Delhi’s ailing power distribution system was plagued by yet another salient issue. Namely, the
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government had to address the unemployment problem that would result from the closure of the plant in
the labour-abundant country of India. The government was spending ₹25 million on employees of the
RPH.19 Raising concerns about the fate of these workers, an official said, “We cannot decommission the
plant [yet] as there are around 300 employees working in it, and transferring them in bulk to other
departments is almost impossible.”20
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DECISION

Following the recommendation of the forum, should the government permanently close down the inefficient
and environmentally hazardous RPH? Or should it continue to operate the plant to preserve the economic
benefits it provides to the city and its people? What side of the problem should receive more weight: the
health and environmental issues or the business and economic activities?
No

Veena Keshav Pailwar is a Professor of Economics at the Institute of Management Technology, Nagpur, India.
Do

17
Ibid.
18
Sweta Goswami, “Rajghat, Badarpur Power Plants to Fire On,” The Hindu, May 30, 2015, accessed August 26, 2015,
www.thehindu.com/news/cities/Delhi/rajghat-badarpur-power-plants-to-fire-on/article7262612.ece.
19
Sweta Goswami, “Rajghat Power House Will Be Shut, but Will Take Time, Says Minister,” op. cit.
20
Ibid.

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EXHIBIT 1: PEAK DEMAND, ENERGY CONSUMPTION, AND ELECTRICITY CONSUMERS IN DELHI

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Year Peak Energy Electricity
Demand Met Consumption Consumers
(MW) (MU) (000s)
2005–06 3,626 21,184 2,838
2006–07 3,736 21,977 2,868

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2007–08 4,030 22,372 3,348
2008–09 4,034 21,768 3,429
2009–10 4,408 23,349 3,777
2010–11 4,720 25,581 4,047
2011–12 5,028 25,593 4,301
2012–13 5,642 27,235 4,464
2013–14 5,653 28,021 4,897

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2014–15 5,925 29,035 5,405

Note: MW = megawatt; MU = million units = a unit of energy equal to one million units of electricity, where one unit is equal to
one kilowatt; 500 MW running for 24 hours gives 12 MUs of energy.
Source: Government of NCT of Delhi, “Energy,” Economic Survey of Delhi, 2014–15, 154–167, accessed October 1, 2015,
http://delhi.gov.in/wps/wcm/connect/1c8dbf8048d8eb34a8dbf97a2b587979/ESD+2014-15+-+Ch-
11.pdf?MOD=AJPERES&lmod=519247184&CACHEID=1c8dbf8048d8eb34a8dbf97a2b587979.
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EXHIBIT 2: ENERGY REQUIREMENT AND PEAK LOAD FORECAST FOR THE NATIONAL CAPITAL
TERRITORY

18th Electric Power Survey National Capital Region Planning


Committee Board
2016–17 2021–22 2016–17 2020–21
Energy Requirement (MU) 37,529 52,930 46,849 59,258
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Peak Load (MW) 6,398 9,024 7,865 9,948

Source: Government of NCT of Delhi, “Energy,” Economic Survey of Delhi, 2014-15, 154–167, accessed October 1, 2015,
http://delhi.gov.in/wps/wcm/connect/1c8dbf8048d8eb34a8dbf97a2b587979/ESD+2014-15+-+Ch-
11.pdf?MOD=AJPERES&lmod=519247184&CACHEID=1c8dbf8048d8eb34a8dbf97a2b587979; National Capital Region
Planning Board, “Power,” Regional Plan 2021, 73–80, accessed October 1, 2015,
http://ncrpb.nic.in/pdf_files/Regional%20Plan%202021%20chapter/11_CH07%20power.pdf.
No
Do

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EXHIBIT 3: SOME SALIENT FEATURES OF POWER DEMAND AND SUPPLY IN DELHI (JUNE 2015)

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Salient Features of Power Stations (in Installed Capacity Generation in MW Plant Load
brackets: Commission Date) in MW (in brackets: Gross Net Factor (%)
Effective Capacity)
Rajghat Power House (RPH) (1989–90) 135 (135) 0.000 -0.575 -1.18
Gas Turbine Power Station (GT) (1986 and

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270 (270) 45.525 43.477 22.87
1996)
Pragati Power Corporation Ltd. (PPCL)
Combined Cycle Gas Power Station (2002– 330 (330) 175.958 171.465 74.05
03)
Badarpur Thermal Power Station (BTPS)
720 (705) 258.294 248.384 94.08
(1973–1981)
Rithala Combined Cycle Gas Turbine (RGT)
108 (108) 0.000 -0.060 -
(2010–11)

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PPCL III—Combined Cycle Gas Power Station
1,500 (1,372) 181.519 174.063 18.16
Bawana (2010–12)
Timarpur Okhla Waste Management Company
16 (16) 13.220 11.316 -
Ltd. (TOWML) (2011–12)
Total 3,079 (2,936) 674.516 648.5875 -
Maximum Unrestricted Demand (MW) 5,846
Peak Demand Met (MW) 5,846
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Peak Availability (MW) 5,648
Energy Consumed During the Month (MU) 3,092.565
Total Load-Shedding (MU) 5.078
Load-Shedding Due to Grid Restrictions 1.490
Load-Shedding Due to Constraints in System 3.588

Source: Delhi Transco Ltd., State Load Dispatch Centre, Progress Report (June 2015), accessed October 7, 2015,
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www.delhisldc.org/Resources%5Cjune%202015.pdf.

EXHIBIT 4: RAJGHAT POWER HOUSE: PERFORMANCE PARAMETERS—TARGET VERSUS


ACTUAL

Target/ 2012–13 2013–14 2014–15 2015–16


Approved/ Actual Actual Actual (up to Estimated
Norm December)
No

Gross Generation (MU) n.a. 792.799 379.883 340.427 889


Auxiliary Power Consumption (%) 11.28 13.27 15.16 15.02 12.50
Net Generation (MU) n.a. 687.577 322.301 289.282 778.208
Availability (%) 75 66.94 65.77 61.12 n.a.
Station Heat Rates (kCal/kWh) 3,200 3,317 3,381 3,359 3,248
Plant Load Factor (%) n.a. 67.04 32.12 57.41 n.a.

Note: n.a. = not available; kCal = kilocalorie; kWh = kilowatt hour.


Source: Indraprastha Power Generation Company Ltd., Tariff Petition for Determination of the Tariff for the Financial Year
2015-16, Approval of Estimates for FY 2014-15 and Truing up for the Previous Period of FY 2012–13 to 2013–14, accessed
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September 29, 2015, www.ipgcl-ppcl.gov.in/documents/2015_03_16_Petition_IPGCL.pdf; Government of NCT of Delhi,


“Energy,” Economic Survey of Delhi, 2014–15, 154–167, accessed October 1, 2015,
http://delhi.gov.in/wps/wcm/connect/1c8dbf8048d8eb34a8dbf97a2b587979/ESD+2014-15+-+Ch-
11.pdf?MOD=AJPERES&lmod=519247184&CACHEID=1c8dbf8048d8eb34a8dbf97a2b587979.

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EXHIBIT 5: COST PER UNIT FOR RAJGHAT POWER HOUSE (₹)

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2014–15 2015–16
Cost in ₹/kWh 2012–13 2013–14
(up to December) (Estimated)
Variable Cost 3.230 3.580 3.610 3.510
Fixed Cost 2.084 4.286 2.231 2.250
Total Cost 5.314 7.866 5.841 5.760

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Source: Indraprastha Power Generation Company Ltd., Tariff Petition, accessed October 7, 2015 www.ipgcl-
ppcl.gov.in/documents/2015_03_16_Petition_IPGCL.pdf.

EXHIBIT 6: PER-UNIT COST OF PROCUREMENT OF POWER FOR DISTRIBUTION COMPANIES IN


DELHI AS FIXED BY DERC (₹)

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Power- BSES Yamuna BSES Rajdhani Tata Power Delhi
NDMC
Generating Power Limited Power Limited Distribution Limited
Companies/ Average Average Average Average
Energy Energy Energy Energy
Stations Rate in Rate Rate in Rate in
(MU) (MU) (MU) (MU)
₹/kWh ₹/kWh ₹/kWh ₹/kWh
NTPC 4,491.15 4.04 9,004.77 4.36 5,931.65 4.25 1,560.34 4.675
NHPC 405.61 3.26 701.36 3.26 489.93 3.26 - -
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NCPP 175.31 3.11 303.14 3.11 211.76 3.11 - -
Other Stations 1,541.88 3.77 1,576.76 3.41 3,716.60 4.06 - -
New Generating
965.52 1.44 482.86 2.06 641.03 1.65 - -
Stations
State Generating
1,028.50 5.13 1,863.22 5.04 1,235.50 5.13 846.98 5.71
Stations
IP Station
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Rajghat 85.06 6.36 149.53 6.36 102.03 6.36 - -


Gas Turbine 267.87 5.27 471.37 5.27 321.21 5.27 - -
Pragati I 435.92 4.20 766.89 4.20 522.57 4.20 750.06 4.20
Pragati III, Bawana 239.64 6.22 414.31 6.22 289.70 6.22 96.92 6.22
TOWMCL - - 60.00 2.60 - - - -
Net Total
8,607.97 3.78 13,930.99 4.18 12,226.47 4.09 - -
(Excluding Solar)
No

Source: Delhi Electricity Regulatory Commission, Tariff Order for FY 2014–15, accessed October 4, 2015, www.derc.gov.in.
Do

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EXHIBIT 7: COST OF GENERATING POWER FOR RAJGHAT POWER HOUSE (₹ MILLION)

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2015–16
Cost Components 2012–13 2013–14 2014–15
(Estimated)
Total Variable Cost (Total Cost of Fuel) 2,220.2 1,155.4 1,073.2 2,730.0
Total Fixed Cost 1,432.8 1,381.5 1,681.8 1,751.3
 O&M Expenses 736.7 726.9 762.1 827.0

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 Depreciation 134.9 132.5 129.6 129.1
 Interest Charges 66.9 63.6 129.6 129.1
 Return on Equity 151.4 157.0 157.7 157.7
 Interest on Working Capital 163.3 113.9 196.7 201.1
 Secondary Fuel Oil 130.6 134.4 317.9 318.8
 Income Tax 49.1 53.3 53.6 53.6
Total Cost (1 + 2) 3,653.0 2,537.0 2,755.0 4,481.0

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Note: O&M Expenses = operating and maintenance expenses.
Source: Compiled from Indraprastha Power Generation Company Ltd., Tariff Petition, accessed January 7, 2015, www.ipgcl-
ppcl.gov.in/documents/2015_03_16_Petition_IPGCL.pdf.
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tC
No
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