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Events in 1993            

14.       On 3rd February 1993 the SIA (the Secretariat of Industrial Approvals, Ministry of Industries) gave industrial approval to Enron, inter alia, on the condition that the “Annual foreign exchange outflow on all counts would not exceed U$ 950 million”. This was against the GOM’s own estimate that the foreign exchange outflow of the project was U$ 1450 million annually, as well as per the CEA in whose estimate the foreign estimate started at U$ 1333 million, annually.

 

15.       In April 1993 Dabhol Power Company (hereinafter referred to as ‘DPC’) prepared a project report and submitted same to the CEA even before notifying the project as required under the law. The details included in the report were considered to be inadequate by the CEA.

 

16.       On 30th of April, the World Bank appraised the project and wrote to the GOI, with a copy sent to Chairman, MSEB. The project when examined by the World Bank was considered unviable and that it would place a heavy financial burden on the MSEB  Further, that the project was inappropriate in the context of the Need and pattern of demand for electricity in Maharashtra. It also suggested that “substantial adjustments” in tariff would be needed in the tariff in order to accommodate the high cost LNG power. The note stated, inter alia, that

“Our analysis based on the parameters provided to us indicates that the LNG-based project as presently formulated is not economically viable, and thus could not be financed by the Bank” (Emphasis supplied)

“(a)   The proposed 2,015 MW project is too large for base load operation in the Maharashtra State Electricity Board (MSEB) system. Project design is inflexible and would result in uneconomic plant dispatch (lower variable cost coal power would be replaced by much higher cost LNG power) in order to utilise the full amount of LNG to be contracted. This adversely affects the economic viability of the project and would place a heavy financial burden on MSEB”; (Emphasis supplied)

“(b)   The project is not part of the least-cost sequence for Maharashtra power development.  Local coal and gas are the preferred choices for base load power generation”.

 

17.       On 28 June 1993, Joseph Sutton Vice President of Enron wrote to Chairman, MSEB in response to the World bank note and increasing press criticism that

“I feel that the World Bank opinion can be changed. We will engage a PR firm during the next trip and hopefully manage the media from here on”(Emphasis supplied)   

18.       On 21/5/93, the GOM’s response to the World Bank’s critique was:

“The note does not support the Project. It, however, points out very clearly that this project would be a very good project if it was not coming up in India” and that  The World Bank presumes that the tariff of the LNG based power project from Enron will be very high”...”We are, however, negotiating strongly with Enron Power Corporation and trying to push down the tariff” 

        Not only was no reduction in the tariff, but in fact, subsequently there was an increase in the “negotiated tariff” after “negotiating strongly”!!!. 

19.       MSEB in an internal note around the same time, forecast a steep decline in efficiency of its own operations and system to justify Enron’s Project.  

20.       These comments and an detailed analysis justifying the project was sent to the World Bank. On 26 July 1993, the World bank replied to the GOI and MSEB in response to their comments on the World Bank note. The bank reiterated its earlier stand and severely criticised the MSEB ‘s attempts to justify the project on grounds that its own system would decline in efficiency..

“... However, we cannot accept the more pessimistic scenario recently provided by MSEB according to which the existing system is projected to decline in efficiency. If this were to be indeed the current best projection, determined actions should be taken with priority to reverse this projected deterioration rather than accepting it as a given fact in the analysis of new investments.”

“...we are finding it difficult to accord supplied justification to the Dhabol project based on the most recently discovered slippages in MSEB’s ongoing and planned least cost progress.”

After extensive further review of the above parameters and detailed review of the analytical frame work and costing assumptions, we reconfirm our earlier conclusion that the Dabhol project as presently formulated is not economically justified and thus could not be financed by the Bank.”

(Emphasis supplied)

 

21.       In August 1993 the CEA conducted a study into the reasonable capital cost of Combined Cycle Gas Turbine plants, like Enron’s  (for evaluating bids for the DESU Bawana project), and found the reasonable cost after considering all relevant factors like currency depreciation, Interest during construction, Inflation etc., to be “Rs. 18130 per kW (December 1996) and Rs. 19160 per kW (December 1997)”. i.e. Rs. 1.81 crores per MW (December 1996 completed costs) and Rs. 1.91 crores per MW (December 1997 completed costs). This is against Enron’s cost (both then and currently) of more than Rs. 4 Crores/MW.

 

22.       In August 1993 in a meeting chaired by Chief Minister, Maharashtra, in reply to the proposition that issues like importing fuel, total foreign exchange outgo and (presumably) tariff etc. “..were minor issues to be clarified” and that “the FIPB would take a decision on them at the time of final review..”, the Union Minister for Power, the Union Minister for Power replied that

“..the project should from the point of view of the existing guidelines with particular reference to two tier tariff”. He also felt that “project need to be technoeconomically appraised and cleared by CEA  before MSEB signs any formal agreement with the Company” (emphasis supplied).

 These “minor issues” were in fact examined by the FIPB and not by the CEA, as will be seen subsequently.

 

23.       On  26 August 1993 Ms. Rebecca Mark, of Enron, expressing satisfaction over the progress of the project, wrote to Shri Sharad Pawar, Chief Minister, Maharashtra stating that

The remaining concern seems to reside with Mr. Beg, Member Planning for Thermal projects. He continues to hold up project approval based on the question of demand for power in Maharashtra. No one from the Ministry of Power in Delhi has given direction to Mr. Beg to move forward on this issue. 

It is clear that the Enron was asking Shri Pawar to intercede and influence a statutory body in the discharge of its duties and/or to get the Ministry of Power to do so against the informed judgment of the expert authority.

 

24.       In September 1993 the Cabinet Note requesting that Cabinet allow MSEB to sign PPA. was finalised. The Note, inter alia, states that Government guidelines require capital costs to be approved by the CEA. Further Tariff figures are discrepant at various different points viz. at very different levels of customs duty, tariff remains same!!!. This clearly points out both the total non-application of mind and a desire to push the project through at all costs.

 

25.       The note had been discussed between MSEB, Department of Energy and Department  of Finance, Government of Maharashtra since July 1993. Various concerns were voiced by the Principal Secretary, Finance. These ought to have been part of the Cabinet Note. However, a separate “secret” note purporting to be the “additional views of the Finance dept.”,. “which remained to be incorporated in the Cabinet Note”  (Emphasis supplied) was drawn up. These “additional views’” are as follows:

“...nor has the project cost projected has been defined as a ceiling project cost.  It is quite possible that in the end, we might end up with cost and time overruns.  Secondly, in terms of the agreements that are going to be executed, there does not appear to be any incentive on behalf of the ENRON  to curtail the project cost.”; “It would be difficult for us to know exactly what the power is going to cost”; “We cannot but feel that the commitment on behalf the MSEB is open in absence of the details...”; “Besides, one cannot help feeling that Enron is not taking any risk whatsoever as a generator of power but wants guaranteed rewards, which is not a very satisfactory arrangement.” (Emphasis supplied)  It went on to say that the Cost of LNG was extremely high and was not known, without which cost of power could not be known.

Further that the project would lead to a “Weakening the credit structure of the MSEB”. (Emphasis in the original )  “The Project envisages the sale of expensive power to HT industrial users via the MSEB with the profits of such sales being earmarked for payment to ENRON on a preferential basis. Incidentally, this amounts roughly to Rs. 250 crore per month.  In fact, any special arrangements made for payment of  cost to ENRON weakens the residual operations of MSEB, which needs to be serviced  by non-HT non-industrial users. This would definitely weaken MSEB and will preclude other MSEB projects from being financed”

“The full set of contractual agreements must be received and finalised, not only the Power Purchase Agreement”.

  

26.       On 10th September 1993, the Secretary (Energy), GOM set the agenda for decision  of the GOI in a letter to the Special Secretary., Power, GOI.. The letter included, inter alia, the following agenda:

“guarantee against change of legislation/ subordinate legislation in respect of allowing foreign private sector investment/ operation of the plant”;

“Suitable amendments to the Electricity Acts to prevent MSEB from restraining the operations of Enron Power Plant; as per the statutory powers conferred upon it.”;

that the  “Structure of the tariff as prescribed under the structure of these acts to be in consonance with the Enron’s tariff structure proposed under the PPA;

that “The DPC will have no obligations to provide information to any authority or MSEB other than those prescribed in the PPA”

and that “the relevant arbitration provisions under the act will not apply to this PPA.” ( All emphasis supplied ).

     As will be seen later, all elements of the above agenda were carried out for the project.

 

27.       On  20 September 1993 the CEA wrote to GOM that “The studies carried out by CEA indicate that the project is not the least cost option”.

 

28.       On 22 September 1993, the notification was published, as required under S. 29 of the Electricity Supply Act, 1948 (herein after referred to as the ESA). The Notification was deficient in material respects. It deliberately misled and misrepresented facts. In particular, in that it stated fuel would be natural Gas (not LIQUEFIED natural gas), thereby suppressing the fact that fuel would be imported at a very high cost and would involve very heavy capital costs for the port, regassification facility etc. This is one of the main reasons why the entire project is so expensive. It also did not specify that it would be using Distillate no 2 but mentions fuel oil (which is substantially cheaper). Further the notification did not mention other salient features like the cost at which power was to be supplied, that the plant was a base load plant, etc. The advertisement invited enquiries for additional information, but all requests for relevant details were refused.

 

29.       In December 1993, the MSEB had purported to carry out an exercise comparing the PPA tariff with normative tariff, purportedly derived through the notified method. The MSEB ’s effort was a blatantly dishonest effort  based on extraneous, untenable and illegal assumptions and it was clear that the MSEB was fraudulently attempting to show the PPA tariffs as lower than the normative tariff.

 

30.       On 2.11.1993, in a meeting of the  FIPB (Foreign Investment Promotion Board) it was noted that  “one of the key issues was the ... reasonableness of the tariff formula” that there had been some criticism of the high cost of power from this project. Further, the meeting noted that the M/power explained that “the Central Electricity Authority would go into the question of reasonability of tariff and the principles of tariff  formula and that “the primary concern remained the question of tariff.” Further that the FIPB was to consider the following issues, inter alia, that “the guaranteed purchase and assumptions about 90% PLF may imply that other stations with cheaper power may have to back down while Dabhol would not”. (Emphasis supplied).

 

31.       The “key issue”  and the “primary concern” about the cost of Power was hastily and perfunctorily disposed of in the following manner. On the following day, 3.11.1993, the Finance Secretary, GOI, took a meeting on Dabhol Power Project to discuss “the tariff for power proposed by M/s Enron”. The minutes record:

“Finance Secretary sought a clarification on the Internal Rate Return (IRR) to equity assumed in the calculations. The Financial Adviser MSEB stated that the normal IRR to investors would be 25.22% and assuming an inflation rate of around 3-4%, the real IRR would be 20.6% at 80% availability. Chairman, MSEB stated that in the negotiations they had attempted to bring down this rate but eventually had accepted this figure. 

The question was raised as to whether this was an unreasonable rate of return. The point was made that a high rate of return could be obtained by keeping down costs and through efficient operations without any adverse effect on the power cost. It was, therefore necessary to consider also the validity of the cost estimates. The Financial Adviser, MSEB stated that they were not competent to comment on capital costs but generally felt that these were not out of line.. 

“Financial Adviser MSEB stated that their assessment was that domestic investors would require a somewhat lower IRR and of this were to be accepted on optimum blended IRR would be between 17-18.3 % in real terms. He clarified that such a reduced IRR could facilitate a negotiation on reduced escalation for capacity charge on the tariff amounting to 0.57 cents/kwh.”  

Finance Secretary enquired regarding the tariff in the Hub River project of Pakistan. Financial Adviser MSEB stated that in the Hub River Project, there was front loading of tariff which declined gradually over the years, the annualised tariff would be 5.9 cents per unit. By way of comparison after excluding import duties and corporate taxes and removing the inflation element, the annualised tariff for Enron would be around 5.71 cents per unit while that for Hub Valley would be 5.4 cents per unit at 75% PLF including 10% import duties. This is arising because of the lower IRR of the Hub river project.”

 

32.       It is critical to place some of these numbers in context

·   The reduction of  0.57 cents/kwh.” in a situation of “a reduced IRR” amounts to U$ 90 million a year (Rs. 300 crores a year). No such “reduction” took place

·   That “the annualised front loaded tariff of Hub Valley (in Pakistan) would be 5.9 cents/unit”. This against annualised 7.5 cents/unit not 5.71 cents as dishonestly represented. The 7.5 cents of the DPC was back loaded. Consequently, the Hub Valley  tariff went down over the years while the Enron’s tariff increased.

·   No one sought to enquire why the IRR (which is lower than the average rate of return) for the Dabhol Project was so high.

·   The IRR mentioned in the minutes works out (very approximately) to over a 32% return on equity. The Law, mandated a 16% return on equity. Every 1% Return on Equity represents a return of U$ 8.5 million (Rs. 28 crores) in a project this size. The overall difference amounts to well over U$ 100 million (Rs. 320 crores then)

 

33.       On 5.11.93, 1993 (recorded in the minutes dated/drawn on 10.11.1993) of the FIPB meeting, based on the earlier discussion, it was recorded that: 

“Finance Secretary observed that that the question of cost of power had been looked into and it had been found that it was more or less in line with other projects being put up in Maharashtra...” (Emphasis supplied)

      It seems incredible that the above casual observation has sufficed to a clear $2.5 billion power project involving a foreign exchange outgo of Rs. 5000 crores a year and in any event is a distortion of fact.  

Further that:

“IV       CEA CLEARANCE”  (Emphasis in the Original) 

“Secretary (Power) indicated that clearance should be available in the week beginning 8th November, 1993” (Emphasis supplied)  

     Interestingly, this would be before the CEA had an occasion to consider the project or for that matter before the minimum statutory period under Section 29 of the Act would have expired.

 

34.       On 8.11.1993, a note was drawn up by the CEA. Some of its observations include:

“Based on 90% dispatch and 76.4% minimum take or buy liability for LNG, the minimum charges payable by MSEB works out to 1334.18 Million Dollars in the year 1998 ..” (Emphasis supplied)  

“The annual total outflow of foreign exchange on all counts is indicated as around US $ 950 million in the SIA approval dated 3.2.93. This issue needs to be taken care of by MSEB.” 

“the return on equity, would work out to about 26% in the 5th year increasing to 52% during the 15th year if the tariff of DPC was adopted for calculations” 

     A comparison of the DPC tariff with the tariff of as calculated under the Law was also made by simply taking prices as “indicated by DPC”

     Even after allowing an ad-hoc incentive for the GOI tariff, the GOI tariff was lower by 14 paisa. The annual difference is of the order of Rs. 220 crores (U$ 70 million a year). Without the ad-hoc incentive the difference works out to an annual difference of the order of Rs. 500 crores, i.e. over the life of the contract, in dollar terms, to nearly U$ 3000 million (Rs. 10,0000 crores) !!!

 

 

35.       The CEA also carried out a study of the backing down of existing generating stations As per the CEA’s analysis, substantial amount of MSEB’s own generating capacity would have to be backed down in order to accommodate the 90% guarantee promised to Enron.  It is to be noted that as per the CEA, 408 MW of MSEB’s generating capacity, in the first year, costing 50 paisa -80 paisa a unit would be backed down to buy 695 MW of Enron’s power @ Rs. 3.47 a unit (per MSEB).

 

36.       DPC repeatedly refused to give the CEA information it asked for.

On 10/11/93, in response to CEA’s questions on the project costs, the DPC replied that

“It is important to note, however, that capital costs are irrelevant to CEA”

Further in response to the CEA asking for specific components involving a expenditure of nearly U$ 2.6 Billion, (Rs. 9000 crores then), the DPC’s response was that

“Your request for more detailed project costs of equipment/system/works other than those provided in the capital cost summary cannot be supported and is not deemed necessary.” (Emphasis supplied) .

 

In reply to the CEA’s queries on “The reasons for the high cost of balance of plant and housing may be furnished”, DPC’s response was

“Same response as question #2 above”. i.e. “Your request ......cannot be supported and is not deemed necessary.”

 

37.       On 11.11.1993, the Secretary (Power, GOI), wrote to Chairman, CEA, extracting Finance Secretary’s observation at FIPB meeting of 5.11.1993. The letter stated that

“Finance Secretary observed that the question of cost of power had been looked into and it had been found that it was more or less in line with other projects being put up in Maharashtra”.

 

38.       The issues before the CEA in considering the clearance of the project included the following

“Issues for consideration for CEA clearance”

·       “Non tying up of essential clearances/inputs by Enron”.

·       “Non-justification of Phase II from power absorption angle”

·       “Costliest option of power generation”.

·       “High risk elements involved in LNG supply contract”.

·       “Consequence of exemption of major deviation from Govt. of India Notification dated 30.3.1992”.

 

39.       On 12/11/93, the CEA met to consider the project’s techno-economic clearance. Extracts from the minutes of the meeting include the following

“The backing down of the existing thermal generation capacity in Maharashtra due to this new capacity addition would imply heavy additional economic costs imposed on the power system of MSEB and these costs needed to be quantified and net economic rate of return from Dabhol project computed.....Keeping in view the costliest option of distillate fuel/LNG, the difference between the cost of LNG based power and the least cost option for Dabhol should be quantified.....The objective should be to minimise the cost of supply of electricity to the consumers in Maharashtra in the context of prevailing low electricity tariff structure in various states including Western Region.”

“CE (TPA) stated that the tariff for sale of power from the project was not as per GOI notification dated 30th March, 1992.  He further stated that in response to request for details of cost estimates, M/s. DPC informed in a letter dated 10.11.93 that the capital cost of the project was irrelevant to CEA because the tariff was guaranteed and changes in capital cost were not passed on to the customer in the tariff.”

“Chairman observed that the Dabhol tariff was a negotiated one and a communication was received from the Ministry of Power informing that the cost of power had been looked into by the Ministry of Finance and found to be more or less in line with other projects being put up in Maharashtra. As such, tariff aspects and deviations with reference to GOI notification and cost estimates could not be examined in the CEA.”

“CE (Commercial) stated that the tariff proposed was a negotiated one and not as per GOI notification or related to the capital cost and payments involved foreign exchange outgo. The return on equity would work out to about 26% in the 5th year increasing to 52% during the 15th year if the tariff of M/s. DPC was adopted for calculations. Exemptions for deviations from GOI tariff notification including return on equity and other aspects would need to be looked into by the Ministry of Power and other concerned agencies of GOI.”

“Member (P) observed that as the World Bank had not agreed to finance the project and there would be a gap of US $ 600 million in the financing plan indicated by M/s. DPC.” 

“Chairman stated that in view of the replies received from M/s. DPC in regard to cost estimates, clarification by the Ministry of Power on financial package and the examination of tariff aspects by Ministry of Finance, examination by CEA would, in effect, get limited to the technical aspects and need for the project  which was already discussed. Chief Engineer (C) expressed the view that given this background, the completed cost would not be considered by CEA at a later stage.”

“After discussions, it was decided that the Ministry of Power might be informed that in view of the fact that the tariff for power from the project was negotiated one and not in conformity with GOI notification, and not related to the capital cost and cost of power from the project had been looked into by the Ministry of Finance, only the technical aspects of the scheme were examined in CEA and found to be generally in order. Formal communication of clearance to technical aspects of the scheme could be given after compliance of Section 29 of the Electricity (Supply) Act , 1948 by M/s. DPC subject to conditions set out therein.” (Emphasis supplied)

 

40.       Thus from the documentary record, it is evident that the CEA consideration of the cost aspects of the Dabhol project resulted in an adverse conclusion drawn on all counts. viz. tariff, rate of return, forex outflow and heavy additional economic costs imposed upon the MSEB. Faced with extraneous pressure to clear the project, the CEA abdicated its statutory responsibility to consider costs in their various aspects on the basis of the above referenced letter dated 11/11/93 from the Secretary, Power, GOI. Thus the CEA acted in breach of its statutory duty in examining only the technical aspects of the scheme, and deciding to accord, only technical clearance. Further that “ that given this background, the completed cost would not be considered by CEA (even) at a later stage.”

 

41.       On 22.11.1993, the 2 month period under S. 29 expired. Various requests for details Including details regarding cost of electricity, capital costs etc., were refused.

 

42.       On 23.11.93,

A.  The GOM wrote to the CEA, enclosing a copy of a letter stating that “ M/s Enron have stated that that they have not received any objections  pursuant to the notification about the proposed Dabhol power project”.

 

B. The CEA on learning that 34 representation were received, faxed a letter to the GOM,  asking “whether Section 29 of the Act was complied with.”

 

C. The MSEB wrote to the CEA that “power purchase agreement, cost details etc. cannot be given to the representationists until project is cleared“

 

D. The Ministry of Power gave an undertaking to the  DPC that “MOP will expedite consideration of all clearances which fall within their competence and ensure that your application for such clearances are approved (Emphasis supplied)

 

43.       On 24.11.93, the GOM (realising that CEA was aware of representations), states that 37 representations (not 34) were received and that Section 29 was complied with.

 

44.       On 26.11.1993, the CEA gave clearance subject to certain conditions. In the letter the CEA specifies that;

 

“aspects relating to import of fuel, foreign exchange outgo and deviation from Government of India’s notification including return on equity was looked into by FIPB and found acceptable by them.”

 

     It must be emphasised that while the clearance given by the CEA was only a technical clearance, it was deliberately and repeatedly misrepresented as the ‘techno-economic clearance. All parties including the GOI, the MSEB, DPC and the CEA have claimed this to be the clearance. on various occasions including to the Cabinet of India, Cabinet of Maharashtra, the Courts, the Parliament and the Press. All the parties now claim that the clearance was granted on 14th July 1994.

 

45.       On 2.12.1993, the Secretary (Energy) GOM, issued a note enclosing CEA’s 26.11.1993 letter, holding that

“This letter conveys full and final techno-economic clearance”  “the project has been fully scrutinised by the Government of India who has now issued their final clearance.”

 

46.       On 6.12.1993, MSEB’s Solicitors clarify that

“The communication dated 26th November, 1993 which has been addressed to Dabhol Power Corporation mentions that the technical aspects of the scheme had been accorded clearance of the CEA subject to certain conditions set out in the letter..”

The question that is required to be considered in the light of the above communications is whether the scheme prepared by DPC for establishment of Combined cycle LNG based Thermal Power Plant of 2015 MW at Dabhol has the required approvals of the CEA as contemplated under the Electricity Supply Act, 1948.

By its communication dated 26th November, 1993 CEA has only cleared the technical aspects subject to conditions which have been reproduced above. It requires to be noted that though in its “in principle” clearance letter CEA had observed that one of the issues to be resolved before the techno-economic clearance would be granted to the Project was the tariff issues in the light of the GOI Notification dated 30th March, 1992. There is no reference in the 26th November, 1993 communication to this aspect except that in paragraph 2 of the letter of CEA it is observed that -

“ The aspects relating to import of fuel, foreign currency exchange outgo and deviation from Government of India’s tariff notification including return on equity have been examined by FIPB and the project had been found acceptable by them.”

It is not clear from the above as to whether CEA itself has examined the issues relating to tariff in the context of the Govt. of India notification dated 30th March, 1992 and found the deviation therefrom acceptable to it.

Approval of tariff by CEA assumes importance in the context of the overall techno-economic clearance of the Project which CEA is required to grant.

As far as the tariff for the sale of electricity by generating company is concerned, the provisions are to be found under section 43A (2) of the Supply Act. The said sub-section provides that the tariff for the sale of electricity by a Generating Company to the Board shall be determined in accordance with the norms regarding operation and the Plant Load Factor as may be laid down by the Authority and in accordance with the rates of Appreciation and reasonable return and such other factors as may be determined, from time to time, by the Central Government, by notification in the Official Gazette.

The Central Government, in exercise of the powers conferred on it by the aforesaid provision by its notification dated 30th March, 1992 determined the factors in accordance with which the tariff for sale of electricity by generating companies to the Board and to other persons shall be determined.

It would be clear that the tariff for the sale of electricity which is agreed upon between DPC and the Board has to strictly conform to the norms laid down in the Government of India notifications. If the tariff does not conform to the criteria then in our opinion it would be necessary for the CEA or the Government of India to specifically approve the tariff. As aforesaid the CEA has not approved the tariff but only noted that the deviation from the tariff notification has been examined and found acceptable by FIPB. This cannot amount to a clearance by the CEA of the PPA tariff formula.

These matters, in our view, are not incapable of resolution especially since the FIPB has, according to the CEA, found the economic aspects of the project acceptable. This however, needs to be perused at the appropriate level in the Government of India. the Board, may in the meanwhile sign the PPA once the Government of Maharashtra approves it pursuant to the Chairman’s request in that regard to the Secretary (Energy), subject to pursuing the matter of a formal Government of India notification relating to the tariff.

 

47.       On 8.12.1993, the Power Purchase Agreement (PPA) was signed. This allowed for the purchase by the MSEB of  695 MW of electrical capacity and/or energy. The 2nd phase was completely optional and non binding on MSEB .

 

Further, on the same day, 8.12.93, the Solicitors of MSEB and DPC issued letters to DPC and MSEB confirming that “...  tariff structure would be formally notified...” under sec 43(A) 2.. of the ESA”.

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