WBSEDCL may have to bear approximately Rs. 6.48 Cr. + Rs. 1.4 Cr. = Rs. 7.88 Cr. extra charge per month when the enacted sharing regulations 2020 of CERC will be implemented. Since this new regulations have violated Article 14 and Article 303(1) of the Constitution of India, WBSEDCL therefore could file a writ petition at Calcutta High Court as per Article 226 of the Constitution of India for a stay of the notified regulations and justified modification of that statute to stop cross subsidy among States and to reinstate “beneficiary-pays” principle.

1. Page 1 of 6
Impact of CERC’s new sharing of inter-State
transmission charges and Losses Regulations
2020 in the bills of WBSEDCL which may have to
bear approx. Rs. 07.88 Cr. extra charge per month
Calculation for the HVDC Part
Before July 2011, inter-State Transmission charge of users was calculated
region wise for five regions separately in postage stamp method where
HVDC charge was allocated to the benefited region. Postage stamp method
means sharing of transmission charge of a region at uniform rate among the
users according to the allocation of transmission capacity to them.
From July 2011 a new hybrid method was introduced following Govt. Tariff
Policy with the intention to share charges rationally according to usage of
inter-State transmission system considering distance, direction and quantum
of power flow. Presently 90% of the charge of AC and HVDC system is
shared in this method which is called as hybrid method since it is a
combination of Average Participation and Marginal Participation Method.
Whereas 10% of the charge is being shared in national postage stamp
method which is termed as Reliability Service Charge.
CERC's new inter-State Transmission Charges and Losses Regulations dated
04.05.2020 introduces socialization of expenditure of national interest with
creation of cross subsidy through postage stamp method against the present
Tariff Policy of usage based sharing. It is understood from Para 13 of Jha
Committee Report that only 22% of the total charge is proposed to be
shared by usage based method (hybrid method) and rest of the charge is
proposed to be shared by postage stamp method (national and regional)
which will definitely allow cross subsidy.
Presently 12.5% of the total YTC of inter-State transmission system is
compromised of charge for HVDC system. Among that, 1.25% is shared by
postage stamp method and rest 11.25% in hybrid method. In the proposed
new method, YTC of total HVDC would be shared by postage stamp method
of which 8% by national postage stamp method and rest 4.5% by regional
postage stamp method. Assuming that both the rate for national postage

2. Page 2 of 6
stamp charge and regional postage stamp charge for HVDC system are
equivalent for West Bengal we could find out approximately how much
charge of West Bengal would be increased for HVDC system in new proposed
method in comparison to the existing method.
Considering October’2019 ERPC Bill
For 10% YTC, postage stamp charge (Reliability Support Charge) is Rs.
31725/- per MW per month. Therefore, for 11.25% YTC the rate would be
Rs.31725/10x11.25= Rs.35,691/- per MW per month.
Present rate in existing PoC method with respect to West Bengal for 11.25%
YTC of HVDC system is Rs.11146/- per MW per month.
For 2467 MW ISGS allocation in respect of West Bengal, charge for 11.25%
of total YTC for HVDC system in two different methods would be as below:
Future postage stamp method: 2467xRs. 35691= Rs. 88049697 ≈ Rs. 8.80 Cr.
Present hybrid method: 2467xRs. 11146= Rs. 27497182≈ Rs. 2.75 Cr
Therefore, it is anticipated that for 11.25% YTC for HVDC system West
Bengal has to bear Rs. 8.80 – Rs. 2.75 = Rs. 6 .05 cr. extra charges per
month in the transmission bill of ERPC
Further, this extra charge will be increased in future with the increase of
long term power purchase of West Bengal.
Considering October’2019 NRPC Bill
For 10% YTC, postage stamp charge (Reliability Support Charge) is Rs.
31725/- per MW per month. Therefore, for 11.25% YTC the rate would be
Rs.31725/10x11.25= Rs.35,691/- per MW per month.
Present rate in existing PoC method with respect to West Bengal for 11.25%
YTC of HVDC system is Rs.44812/- per MW per month.
For 600 MW injections in respect of West Bengal, charge for 11.25% of total
YTC for HVDC system in two different methods would be as below:
Future postage stamp method: 600xRs. 35691= Rs. 21414600 ≈ Rs. 2.14 Cr.
Present hybrid method: 600xRs. 44812= Rs. 26887200≈ Rs. 2.69 Cr

3. Page 3 of 6
Therefore, it is anticipated that for 11.25% YTC for HVDC system West
Bengal has to bear Rs. 2.69 – Rs. 2.14 = Rs. 0 .55 cr. less charges per
month in the transmission bill of NRPC
Considering October’2019 WRPC Bill
For 10% YTC, postage stamp charge (Reliability Support Charge) is Rs.
31725/- per MW per month. Therefore, for 11.25% YTC the rate would be
Rs.31725/10x11.25= Rs.35,691/- per MW per month.
Present rate in existing PoC method with respect to West Bengal for 11.25%
YTC of HVDC system is Rs.11146/- per MW per month.
For 400 MW injections in respect of West Bengal, charge for 11.25% of total
YTC for HVDC system in two different methods would be as below:
Future Postage stamp method: 400xRs. 35691= Rs. 14276400 ≈ Rs. 1.43 Cr.
Present hybrid method: 400xRs. 11146= Rs. 4458400≈ Rs. 0.45 Cr
Therefore, it is anticipated that for 11.25% YTC for HVDC system West
Bengal has to bear Rs. 1.43 – Rs. 0.45 = Rs. 0 .98 cr. extra charges per
month in the transmission bill of WRPC
NET effect for 11.25 % of total YTC comprises of HVDC transmission
West Bengal has to pay approximately Rs. 6.05 Cr- Rs. 0.55 Cr + Rs. 0.98
Cr = Rs. 6.48 Cr extra charge per month in respect of part of
HVDC system of inter-State transmission if the enacted sharing of inter-
State transmission charges and losses regulations 2020 of Central Electricity
Regulatory Commission is implemented.

4. Page 4 of 6
Calculation for the AC Part
Presently only 8.75% of total YTC compromises of AC transmission system is
shared by national postage stamp method and 78.75% of total YTC
compromises of AC transmission system is shared by hybrid method. It is
understood from a RTI-reply of CERC that 56% of total YTC compromises of
AC transmission system shall be shared by national postage stamp method if
the draft is enacted as it is proposed. Which means 56%-8.75%=47.25% of
total YTC compromises of AC transmission system shall be shared in national
postage stamp method in excess of present 8.75%. Let us calculate and
compare the effect of that change:
ERPC October 2019 Bill
Present rate in existing PoC method with respect to West Bengal for 78.75%
of total YTC of AC transmission system is Rs.310261/- per MW per month.
Rate for 47.25% will be (310261/78.75) x 47.25=Rs. 186157/MW/month.
The monthly charge for 2467 MW drawal will be,
2467 x 186157 = Rs. 459249319/- ≈ Rs. 45.92 Cr.
For 10% YTC, postage stamp charge (Reliability Support Charge) is Rs.
31725/- per MW per month. Therefore, for 47.25% YTC the rate would be
Rs.(31725/10) x 47.25= Rs.149901/- per MW per month.
The monthly charge for 2467 MW drawal will be,
2467 x 149901 = Rs. 369805767/- ≈ Rs. 36.98 Cr
Reduction in monthly charge in proposed method = 45.92 – 36.98 = Rs.
8.94 Cr

5. Page 5 of 6
WRPC October 2019 Bill
Present rate in existing PoC method with respect to West Bengal for 78.75%
of total YTC of AC transmission system is Rs.77565/- per MW per month.
Rate for 47.25% will be (77565/78.75) x 47.25=Rs. 46539/MW/month.
The monthly charge for 400 MW injections will be,
400 x 46539 = Rs. 18615600/- ≈ Rs. 1.86 Cr Cr.
For 10% YTC, postage stamp charge (Reliability Support Charge) is Rs.
31725/- per MW per month. Therefore, for 47.25% YTC the rate would be
Rs.(31725/10) x 47.25= Rs.149901/- per MW per month.
The monthly charge for 400 MW injections will be,
400 x 149901 = Rs. 59960400/- ≈ Rs. 6.00 Cr
Increase in monthly charge in proposed method = 6.00-1.86 = Rs. 4.14 Cr
NRPC October 2019 Bill
Present rate in existing PoC method with respect to West Bengal for 78.75%
of total YTC of AC transmission system is Rs.77565/- per MW per month.
Rate for 47.25% will be (77565/78.75) x 47.25=Rs. 46539/MW/month.
The monthly charge for 600 MW injections will be,
600 x 46539 = Rs. 27923400/- ≈ Rs. 2.79 Cr Cr.
For 10% YTC, postage stamp charge (Reliability Support Charge) is Rs.
31725/- per MW per month. Therefore, for 47.25% YTC the rate would be
Rs.(31725/10) x 47.25= Rs.149901/- per MW per month.
The monthly charge for 600 MW injections will be,
600 x 149901 = Rs. 89940600/- ≈ Rs. 8.99 Cr
Increase in monthly charge in proposed method = 8.99-2.79 = Rs. 6.20 Cr

6. Page 6 of 6
Net effect for 47.25% of total YTC comprises of AC transmission
West Bengal has to pay approximately Rs.4.14 cr+ Rs.6.20 cr – Rs. 8.94 cr.
= Rs. 1.4 Cr extra charge per month in respect of part of AC
transmission system if the enacted sharing of inter-State transmission
charges and losses regulations 2020 of Central Electricity Regulatory
Commission is implemented.
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Conclusion
WBSEDCL may have to bear approximately Rs. 6.48 Cr.
+ Rs. 1.4 Cr. = Rs. 7.88 Cr. extra charge per month
when the enacted sharing regulations 2020 of CERC will
be implemented. Since this new regulations have violated
Article 14 and Article 303(1) of the Constitution of India,
WBSEDCL therefore could file a writ petition at Calcutta
High Court as per Article 226 of the Constitution of India
for a stay of the notified regulations and justified
modification of that statute to stop cross subsidy among
States and to reinstate “beneficiary-pays” principle.
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