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### Design Energy Reassessment by CEA is Mandatory to Determine Tariff Adjustments Following a Change in Law Event

M/s JSW Hydro Energy Limited v. Himachal Pradesh Electricity Regulatory Commission & Anr. [Appeal No. 327 of 2021 & IA No. 1237 of 2025.]

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THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant, operator of the Baspa-II (300MW) hydroelectric project, sought a declaration that notifications increasing the mandatory minimum water discharge from 5 cusecs to 15% of the minimum inflow (~0.72 cumecs) constituted a "Change in Law" event under the Power Purchase Agreement (PPA)

Source reference: p. 2, para. 1

In the impugned order dated 28.09.2021, the Himachal Pradesh Electricity Regulatory Commission (HPERC) recognized the Change in Law but denied tariff adjustments

Source reference: p. 3, para. 3

HPERC reasoned that actual energy generation had exceeded the "Design Energy" (DE) specified in the PPA, meaning no financial loss was incurred

Source reference: p. 3, para. 3

During the pendency of the appeal, a subsequent HPERC order dated 01.04.2025 directed the Central Electricity Authority (CEA) to reassess the project's DE for the 2024–2029 control period due to historical over-generation

Source reference: p. 5-7, para. 8
02

Issues

1. Whether there is an increase in the minimum discharge obligation of the project as a result of a Change in Law

Source reference: p. 2, para. 2

2. Whether the Petitioner is entitled to a revision of energy charges/tariff adjustment on account of the increased mandatory water release, particularly regarding the reduction of saleable design energy from January 2021

Source reference: p. 3, para. 2-3
03

Law Applied

The Tribunal applied Clause 20.21(b)(ii) of the Power Purchase Agreement (PPA), which defines "Change in Law" events and the subsequent entitlement to financial compensation or tariff adjustment

Source reference: p. 3, para. 3

Procedurally, the Tribunal relied on the regulatory principle that the Central Electricity Authority (CEA), having originally accorded Techno-Economic Clearance (TEC), is the competent technical body to compute and revise "Design Energy" based on hydrological data and statutory environmental mandates

Source reference: p. 5, para. 8
04

Reasoning

The Commission had initially denied relief because the project's actual generation was higher than the PPA's Design Energy, concluding no impact on cost

Source reference: p. 3, para. 3

However, the Appellant argued that the net saleable design energy for tariff calculation should be reduced (from 1213.18 MUs to 1028 MUs) to reflect the higher water discharge obligation

Source reference: p. 3-4, para. 4

The Tribunal noted that HPERC itself, in a later proceeding, had acknowledged that the project’s hydrological series needed review and had referred the matter to the CEA for the 2024–2029 period

Source reference: p. 5-6, para. 8

The Tribunal reasoned that since a technical assessment by the CEA was already mandated for future years, the same expertise should be applied to determine the specific impact of the Change in Law on Design Energy and net saleable energy retrospectively from January 2021

Source reference: p. 7-8, para. 12-13
05

Holding

The Tribunal set aside the impugned order regarding Issue No. 2

It directed the CEA-constituted committee to analyze past hydrological data and compute the impact of the Change in Law on the project’s Design Energy and net saleable energy effective from January 2021

Source reference: p. 8, para. 13

The committee must submit its report to the CEA and the Commission within three months, following which the Commission shall determine the consequential tariff adjustment/relief

Source reference: p. 8, para. 13-14

The appeal was disposed of with directions to the Directorate of Energy (HP) to provide all necessary records to the CEA within 15 days

Source reference: p. 8, para. 15-16
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M/s JSW Hydro Energy Limited v. Himachal Pradesh Electricity Regulatory Commission & Anr. [Appeal No. 327 of 2021 & IA No. 1237 of 2025.]

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