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TARIFF PHILOSOPHY PAPER OF M.P.E.R.C.
DETERMINATION OF
REVENUE REQUIREMENT
- Regulatory process of tariff
determination consists of two steps. The first step is
determination of revenue requirement of the utility. The second
step is design of tariff elements which, when multiplied by sales,
produce the allowed revenue that the utility can collect from
customers. The allowed revenue should be equal to the revenue
requirement to enable the utility to recover its costs. Unless the
utility realises costs, including a reasonable return on its
investment, the utility will be unable to attract the capital
needed to maintain and expand the system. However, if the utility
fails to check and eliminate theft and pilferage of power and
reduce level of inefficiency, the financial burden thereof should
not be allowed to pass on to the consumers.
- There are three general
approaches for determining the revenue requirement and the revenue
allowed by the Commission
- actual historic accounted
costs and sales volumes;
- estimated future costs and
forecast loads; and
- estimated marginal costs
(usually long-run incremental costs) and forecast loads.
- The main difference between
these approaches is in the choice of a "test year," i.e., the
period over which the Commission measures utility's cost of supply
and sales.
- HISTORIC TEST YEAR
- Under the first approach, the
Commission defines a specific 12-month period in the recent past
as the historic test year, which may become the basis for
assessing the costs of supply and sales of power. The costs and
sales of the historic test year may be then adjusted for "known
and measurable changes". Examples of known and measurable
changes are an increase in power purchase cost due to a new PPA,
a change in tax laws, or a decrease in load due to an exit from
the system of a major industrial customer.
- The historic test year
approach does have disadvantages. Because this approach relies
primarily on a past year's costs, it may be in consonance with
the Act, in cases where the entity can produce credible
projections of its costs and sales. However, since the tariffs
decided are to be made effective in the future time period and
the level of costs incurred and sales experienced in the
historic test year may not correspond with costs and sales
expected to be incurred during that future period, based on
performance of utility it may be more appropriate to use a
future test year as the basis for revenue requirement and
allowed revenue determination.
- FUTURE TEST YEAR
- The future test year approach
uses a forecast of future costs and future load expected in a
specific 12-month period during which the new tariffs will be in
effect. While the forecast may rely heavily on past experience,
all expected changes, such as inefficiency in operation of
utility, its failure to check theft, pilferage and wastage of
electricity or recovery of dues, and not just the "known and
measurable" are incorporated. This approach may be closer to
what is contemplated in the Act, but the entity may not be able
to forecast costs with a sufficient degree of reliability.
- LONG-RUN INCREMENTAL COSTS
- In an attempt to mimic
market-based pricing, Commission sometimes uses long-run
incremental costs (LRIC) in setting the revenue requirement.
LRIC reflect the cost of expanding the system efficiently to
satisfy the load forecast, over a long time horizon. However,
use of LRIC for this purpose raises some very real practical
problems, specially with respect to investments to be made in
order to achieve the desired physical targets. Estimation of
LRIC is difficult and sensitive to many subjective assumptions
that must be made during the estimation process. As a result,
the estimated costs, and therefore the revenue requirement, can
vary significantly, depending on the assumptions made. Revenue
derived by charging LRIC as prices on estimated future sales
can, thus, differ from the amount actually required to meet the
financial needs of the entity. This could either place the
financial viability of the entity in jeopardy or bestow a
significant windfall upon it.
- While the Commission recognizes
the benefits of tariff that reflect current costs either through
the use of a Future Test Year or marginal costs, it appreciates
the desirability of being able to audit historical costs and the
stability of the resulting tariffs. The Commission proposes to
utilize the current methodology of Future Test Year (Ensuing Year)
relying mainly on the past and current year's achievements.
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