1. 1
Part-1 : Understanding Genesis of Tariffs
and it’s structures.
Part-2 : Impact on Bottom line on day-to-
day activities
Based on CERC Tariff Regulation 2019-24
2. • We will create a plant of 1000MW
Learn how Tariff is determined and
we get back our return and also make profit
How to become a rich person
3. 3
Any Business Model
• Investment of Capital
• Creation of Facility / Resources
• Maintenance of Facility/ Resources so that it can create it can Cost you are incurring
generate revenue in turn profit (Working Capital)
• Return of the investment
• Capacity Charges in the name of Annual Fixed Charge Charge you are recovering from Customer
• Variable Expenses
• Cost of Fuel consumption (Both Coal, Oil), APC and Reagents( Limestone)
• Return of Variable expenses in the name of ECR
4. 4
Business Model of ISGS
• How do a business is started ?
• Capital for creating the Fixed assets like Land, equipment etc.
• Equity (30%)
• Debt (70%) Cost
• Capital required to Continue the business
• Working Capital
• How de we get the return of my capital invested and get profit ?
• We get the return in two parts
• As capacity charge, we get the capital employed
• Servicing of Capital employed (Fixed Charge / Capacity Charge) (DORII-mon CSS)
Charge
• Return on Equity (ROE 15.5% or 16.5%)
• Interest on loan capital at actual
• Depreciation (getting back the capital deployed) @5.28% for initial 12 years (63.36%)
and balance to get back equally during balance period of life (2.05%)
5. 5
Business Model of ISGS
• Interest on working Capital : Fuel, Inventory, Receivable and O&M expenses ) required to continue the
business. (FIR on O&M)
• O&M Expenses expenditure on manpower, repairs and maintenance spares, consumables
(chemicals), insurance and overheads and fuel other than used for generation of electricity etc.
(Employee cost, R&M cost, Overhead, CC Expenses) (Repair and maintenance of EOC)
• Overhead (Power charges, Chemical Consumptions, Insurance Premiums, Boiler licence fee, Training
expenses, Technical studies (EMG), Education expenses, Inland travel expenses, tender expenses, guest
house expenses, IT expenses (consumables, UPL and contract employees), Legal expenses etc.
• Variable Charges [Energy Charge Rate (ECR)]
ECR = {[(SHR – SFC x CVSF) x LPPF / (CVPF) }+ {SFC x LPSFi} + {LC x LPL}] x {100 /(100 –
AUX)}
We get back the cost of primary fuel, Secondary fuel, Auxiliary power consumption and Cost of
Reagents (limestone)
6. Capacity
Charge
Interest
on Debt
(IOD) At
actual
ROE
(15.5/
16.5%)
Deprecia
tion
(@5.28
% for 12
years)
63.36%
O&M Cost
(lac/MW)
Interest
on
Working
Capital
(@MCLR
of
SBI+3.5
%)
Special
Allowance
@9.5
lac/MW –
after the
completion
of useful life
of plant (25
years, No
escalation )
Expenses
toward
Security of
facility i.e.
plant,
township
Charges
RLDC/CERC
/Water
Determination of Tariff – Basic terms
DORII-Mon CSS
Target Availability
of 85%
8. 9
Business Model of ISGS
• IDC – Interest during construction
• IEDC – Incidental Expenses during construction, Administrative expenses
• Initial Capital Spares (4% of Plant and machinery cost)
• Land
• Equipments Water Security (CISF)
• Environmental studies (Environmental Impact studies)
• Tariff Filing charges (CERC - Central Electricity Regulatory Commission)
• RLDC Charges (Regional Load Despatch Centre)
9. Basic Definitions
• Frequency
• Capacity
• ISGS = Inter State generating Station
• Beneficiaries who are entitled to get power from a station
• Generation ( Million kWh) (500 MW x 24 Hr/1000 = 12 mu)
• PLF (%) = Gross generation at generator output terminal / (Name plate Capacity)
• DC (%) = Power which is committed to be supplied on a particular time (block) from the boundary
of plant by the generator
• SG (%) = Power which is scheduled by beneficiaries on a particular time (block) from the boundary
of plant
• AG (%) = Power which is actually supplied to beneficiaries on a particular time (block) from the
boundary of plan
• Heat Rate (kCal/kWh) = Amount of heat energy from fuel is required for generation of one unit of
electrical energy
• APC(%) = Energy consumed by auxiliary equipment / (Gross Generation)
• DSM (Deviation settlement Mechanism), RLDC, SLDC
Hz RPM
10. 11
Basic Definitions
• Concept of Normative
• Parameters for which specific values are mentioned in regulation e.g Heat rate, APC, ROE
• Repair and Maintenance (R&M)
• Regular maintenance of plant equipment (spares and contract cost).
• Renovation and Modernization (R&M)
• On completion of plant life, we are entitled to do Renovation and Modernization
• Appellate Tribunal and CERC
• Appellate Tribunal for Electricity has been established by Central Government for those who are not
satisfied with the Central Electricity Regulatory Commission’s order or with an order of SERC. The Tribunal
has the authority to overrule or amend that order.
• The tribunal must be approached within 45 days from getting the order by the aggrieved person.
11. 12
PROCESS OF POWER GENERATION
Declare Get Schedule Generate
DC SG AG
Punching by SCE RLDC to SLDC SLDC to Discoms
Discoms to SLDC SLDC to RLDC RLDC to Generator
12. 13
PROCESS OF BILLING
Generator
Monday SEM data
Special Energy Meter
(EEMG)
RLDC Verification of data
Uploads verified data
in RLDC Site
SEM RPC
RPC calculates DSM
(Regional Power
Committee)
Uploads the Energy
accounting
Generator verifies
(EEMG)
Takes approval for
payment / receipt
CC-Commercial does
billing
Generator
Monday SEM data
Special Energy Meter
(EEMG)
RLDC Verification of data
Uploads verified data
in RLDC Site
13. 24
Arriving at Capital Cost
Capital cost (Normative basis)
All the expenditure incurred or projected to be incurred till SCOD for land and Plant &
Machinery
IDC (Interest on the capital employed during construction stages, to be incurred from the
actual date of infusion of debt Prudent phasing of fund)
IEDC (pre-operative expenses e.g. salary, administrative expenses), to be paid from zero
date i.e. date of commencement of project mentioned in Investment approval / date of
investment approval upto SCOD envisaged in Investment approval or agreed in PPA
Initial Capital spares (limiting to 4% of plant and machinery cost for coal / Hydro / Gas) at
actual
Adjustment of revenue in excess of fuel cost due to sale of infirm power prior to COD,
Interest on deposits and LD recovered from agency
No Energy charge will be received for infirm power (earlier Rs.1.78 / kWhr capping)
24
CERC Tariff Regulation 2019-24
14. 25
Arriving at Capital Cost
Capital cost (Normative basis) Exclusions
• The assets forming part of the project, but not in use (Hydrogen Generation
plant)
• Decapitalisation of Asset
• the proportionate cost of land which is being used for generating renewable
energy
• Provided that any grant received from the Central or State Government or any
statutory body or authority for the execution of the project which does not carry
any liability of repayment shall be excluded from the Capital Cost for the purpose
of computation of interest on loan, return on equity and depreciation
25
CERC Tariff Regulation 2019-24
15. 26
Prudence check of Capital Cost for new stations
Prudence check generally includes scrutiny of the capital expenditure, financing plan,
interest during construction, incidental expenditure during construction for its
reasonableness, use of efficient technology, cost over-run and time over-run etc.
Capital Cost prudence check w.r.t benchmark norms specified / to be specified by
Commission from time to time.
CERC has already issued an order on Benchmarking of capital cost for different unit
size and unit configurations.
26
Unit Size in
MW
No of
units
Total Hard cost
(Rs. Cr/ MW)
Unit Size in MW No of units Total Hard cost
(Rs. Cr/ MW)
500
(Greenfield)
1 to 4 5.08 -4.34 660
(Greenfield)
1 to 4 5.37-4.37
500
(Extension)
1 to 2 4.92-4.53 660
(Extension)
1 to 2 4.95-4.67
600
(Greenfield)
1 to 4 4.87-4.01 800
(Greenfield)
1 to 4 4.96-4.44
600
(Extension)
1 to 2 4.47-4.19 800
(Extension)
1 to 2 4.63-4.44
CERC Tariff Regulation 2019-24
16. 27
IDC/ IEDC- in case of delay in projects
• Additional IDC due to delay beyond SCOD will be allowed only after
prudence check.
• Additional IDC & IEDC will be allowed only for delay due to uncontrollable
factors such as:
• Force Majeure
• Change in Law
• If the delay is attributable to agencies or contractors, no IDC/ IEDC will be
allowed for the delay period
CERC Tariff Regulation 2019-24
17. 33
Truing up for 2014-19
Truing up exercise based on actual CAPEX upto
31.03.2019 for tariff period 2014-19 to be done with the
new Tariff petition for 2019-24 latest by 31.10.2019
The capital cost admitted after truing up as on
31.03.2019 will be the opening capital cost for Tariff
period 2019-24 for determination of tariff for 2019-24
Difference between tariff allowed and revised after
Truing-up to be adjusted with simple interest at the
bank rate as on 1st April of respective year in six equal
monthly instalments
33
18. 34
Truing up for 2019-24
Truing up exercise based on actual CAPEX for tariff period
2019-24 to be done with the new Tariff petition for 2024-29
Generating company has to make an application for Truing
up latest by 30.11.2024
Generating company can apply for interim truing up in the
year 2021-22 if actual Fixed cost is more than 20% as
envisaged in Tariff Notification. However, if it is less, it is to
be reimbursed with interest at bank rate to beneficiaries
without going to CERC
Difference between tariff allowed and revised after Truing-up
to be adjusted with simple interest at the bank rate as on 1st
April of respective year in six equal monthly instalments
34
19. 35
Return on Equity (ROE)
35
CERC Tariff Regulation 2019-24
Rate of return on equity (Base rate - Post-tax) retained at 15.5% (thermal),
16.5% (hydro- storage & pumped storage).
Ramp rate requirements for thermal (w.e.f 01.04.2020)- new provision
Reduction in rate of ROE by 0.25% for not achieving ramp rate of 1% per
min.
Additional ROE @ 0.25% for every incremental ramp rate of 1% per min
achieved subject to ceiling of 1%.
RGMO/FGMO, data telemetry, communication system up to LDC, protection
system mandatory for existing/new projects – Otherwise, Rate of RoE may
be reduced by 1% for the period of deficiency as decided by CERC based on
report by RLDC.
20. 36
Return on Equity- treatment of tax
Tax to be paid by the generator
Mechanism of recovery of tax paid is through grossing up
of the Base Rate of Return
Actual tax rate to be used for grossing up purpose.
36
CERC Tariff Regulation 2019-24
Example:
If estimated effective Income Tax rate is 25% to be calculated at the
beginning of every year based on estimated profit and tax to be
paid, then Pre-Tax Grossed up ROE would be 15.5%/(1-25%) =
20.67%
Grossed up ROE will be trued up at the end of each financial year
based on actual income tax paid
D/E ratio retained at 70:30
Equity in excess of Normative (30%) treated as deemed loan and if Equity
less than 30%, ROE shall be given on actual equity.
21. 37
37
To be charged from 1st year of CoD irrespective of moratorium @ Actual Wt. Avg. Rate of interest at
the beginning of each year
The repayment shall be considered as equal to the depreciation allowed in the previous year.
Generator to attempt re-financing - Net Benefit of refinancing to be shared in the ratio of 1 (Gen):2
(beneficiaries); Refinancing cost is to be borne by the beneficiaries
Why should we try to do COD at the earliest ?
Interest on Loan
CERC Tariff Regulation 2014-19
22. 38
38
Why should we commercialize early?
S. No. Unit size
(MW)
Likely Loss
(Rs. Cr /month of delay)
1 500 24
2 660 30
3 800 36
23. 39
39
Why is depreciation given at all ?
Depreciable value 90% (except land) ; 100% for IT components
Depreciable life:
Thermal - 25 years
Gas –25 years
Hydro - 40 years (35) years
5.28% for the first 12 years after commercial operation and rest shall be
spread over balance life
Depreciation
24. 40
Interest on Working Capital
40
• Coal Based Stations
o Cost of Coal stock for 10 (15 ) days for pit head stations, 20 (30 days) days
for non-pit head stations for normative plant availability ( 30 days for gas station)
or maximum coal storage capacity, whichever is lower
o Advance payment for 30 days towards cost of coal for normative plant
availability
o Secondary fuel oil (for main Secondary fuel) for 2 months for normative
consumption
o Maintenance spares @ 20% (coal) / 30% (gas) of O&M (Inventory) cost
including Water charges and security expenses
o Receivables for 45 days (60 days) (capacity charge and energy charge) on
normative PAF
o O&M expenses including water charges and security expenses for 1 month
• Cost of fuel – Coal cost for IWC computation to be based on actuals of the 3rd quarter of
preceding year for every year and for new stations cost for the first year will be the landed
cost of coal during three months prior to COD i.e for infirm power generation.
CERC Tariff Regulation 2014-19
25. 41
Interest on Working Capital
41
• Rate of interest will be bank rate as on 1.4.2019 or 1st of
April of the year in which the station is declared under
commercial operation whichever is later (Bank Rate (SBI) is
MCLR plus 350 point basis . MCLR- Marginal cost based lending
rates refers to the minimum interest rate of a bank below
which it cannot lend, except in some cases allowed by the RBI
• In case of truing-up, the rate of interest on working capital
shall be considered at bank rate as on 1st April of each of
the financial year during the tariff period 2019-24.
• IWC will be paid on normative basis irrespective of whether
generating company taken loan or not?
CERC Tariff Regulation 2014-19
26. Input price of coal in case of integrated mines
• If the generating company has been allocated the coal block and is
extracting coal which is used for generation in one or more generating
stations of the company, separate tariff order will be issued for
determining the coal rates by CERC.
• However, till the time no Tariff order is issued, coal rates as notified by
Coal India will be used for the purpose of ECR calculation.
• However, the reconciliation will be done after declaration of tariff and
receipt or reimbursement will be done to beneficiary.
27. 43
43
Employee cost
Repair & Maintenances
Overhead (Power charges, Chemical Consumptions, Insurance Premiums, Boiler licence
fees, Training expenses, Technical studies (EMG), Education expenses, Inland travel
expenses, tender expenses, guest house expenses, IT expenses (consumables, UPL and
contract employees) Legal expenses
CC Expenses
Water and Pollution cess,
RLDC Charges, water charges, security expenses, Tariff filing fees
Capital spares cost for replenishment of initial capital spares
Components of O&M Expenses
28. 45
45
O&M Expenses
CERC Tariff Regulation 2019-24
Security expenses to be allowed separately after prudence check (Similar to water charges & capital
spares). Generator to submit assessment of security requirement & estimated expenses.
Additional units after first 4 units declared COD after 01.04.2019 – 90% of O&M expenses norms
Annual escalation: Thermal - 3.5% (6.35% p.a. in Reg. 2014); Hydro – 4.77%
O&M expenses for ECS (Emission Control System) to be notified separately. Till such time, to be decided
on case to case basis.
Security Exp.- Separate account to be kept. All CISF & other security Exp. (including housing, medical, etc.
related to security) to be booked separately.
Year wise O&M expenses for different unit sizes for 2019-24 Tariff notifications
O&M Expenses 2019-20 2020-21 2021-22 2022-23 2023-24
200 / 250 MW 32.96 34.11 35.31 36.54 37.82
500 MW 22.51 23.30 24.11 24.96 25.83
660 MW and above 20.26 20.97 21.70 22.46 23.25
800 MW and above 18.23 18.87 19.53 20.21 20.92
29. High Demand Season
3 months – (Consecutive or otherwise)
Low Demand Season
9 months –(consecutive or otherwise)
Peak Hours (4 hours in a day)
Target Availability of 85% to be achieved on
cumulative basis for 3 months
Peak Hours (4 hours in a day)
85% Target Availability to be achieved. (on
cumulative basis for 9 months)
Off-Peak Hours (20 hours in a day)
85% Target Availability to be achieved on
cumulative basis for 3 months
Any under-achievement in availability during
off-peak hrs can be off-set by over-
achievement in peak hours during high
demand season.
Off-Peak Hours (20 hours in a day)
85% Target Availability to be achieved (on
cumulative basis for 9 months)
Any under achievement in availability in off-
peak hrs can be off-set by over-achievement in
peak hours during low demand season.
Target Availability – Reg. 42
AFC split into capacity charges for High Demand Season and Low Demand Season (w.e.f 01.04.2020)
Concerned RLDCs shall notify high / low demand months at least 6 months in advance.
Peak hours to be declared by RLDC at least 1 week in advance -20% of monthly fixed charges are
to be recovered in peak hrs
30. Strategy
1.0 No overhauling during high demand season
2.0 For units under RSD, we can’t give DC more than 100%
3. In coal shortage scenario, stations can minimize under recovery of AFC by declaring higher DC (>85%) in peak
hrs.
Peak Hours 16.67% of the day and Off Peak hours 83.33% of the day
Suppose we have annual AFC 120 Cr.
To be recovered in High Demand season Rs.30 Cr and Low demand season Rs.90 Cr.
High Demand Season : During Peak hours (16.67%), 20% of 30 cr. = Rs.6 Cr and During Off peak hours 24 Crores
Low Demand Season : During Peak hours (16.67%), 20% of 90 cr. = Rs.18 Cr and During Off peak hours 72 Crores
31. Incentive Reg.- 42 (6)
Applicable on achieving Normative Annual Plant Loading Factor (NAPLF calculated based on
Ex-bus SG) of 85% on a cumulative basis within each Season (High Demand or Low Demand
Season) (wef 01.04.2020) (Months for Season may be continuous or discrete)
Plant Load factor for Incentive = SG/[IC*(1-NAPC/100)]
Differential incentive rate for peak / off-peak hours (wef 01.04.2020)
Incentive @65 paisa/kwh during Peak hours
Incentive @50 paisa/kwh during off-peak hours
Capacity charges and incentives shall have to be recovered on season basis
Strategy : At any time, we should declare higher DC during peak hours that may lead to earning
higher incentive in particular at the time of difficulty i.e. coal shortage, unit problems etc.
32. APC - Reg.- 49(E)
Unit / Station APC Comparison with Tariff Regulations 2014
200 MW 8.5% No change
500 MW & above - With TDBFP
- With MDBFP
5.75%
8%
increase by 0.50%
increase by 0.25%
Additional APC:
1. Tube type coal mill (Talcher-I, VSTPS-2 & Unchahar-2)
2. IDCT
3. Air Cooled Condenser – Direct / Indirect cooling
0.8 %
0.5%
1% / 0.5%
Provided in Tariff Regulations 2019
No change
No change
Gas stations (CC) –
With electric motor driven Gas Booster Compressor
Additional APC for ACC (direct cooling with mechanical
draft fans)
2.75%
2.95%
0.35%
Increase by 0.25%
Tanda 11.5% Reduced by 0.5%
APC for ECS (Emission Control System), Sewage Treatment Plant and External CHP (Jetty & associated
infrastructure) to be considered separately.
APC shall not include colony consumption, construction power and consumption by integrated coal mine.
However, CERC in the SOR has clarified that generating stations shall continue to draw power from the
station for colony consumption.
33. 50
Renovation and Modernization
50
CERC Tariff Regulation 2019-24
R&M
Generating company intending to undertake R&M shall
obtain consent of the beneficiaries and submit the same
along with the petition to the Commission.
34. 51
Special Allowance
• Alternatively, the generating company may opt to avail
‘Special Allowance’ (SA). In such a case:
• Will be allowed for units completing 25 years from COD
Special allowance @9.5 Lakh/MW without escalation for the
tariff period 2019-24. (18-19: 9.59 L/MW 6.35% escalation)
Special Allowance to be transferred to a separate fund for
utilization towards R&M activities, for which a detailed
methodology shall be issued separately.
51
CERC Tariff Regulation 2019-24
40. 57
• Computation of Energy charges (EC)
- Cost of primary and secondary fuel,
- Cost of limestone and any other reagent
• EC covering primary fuel cost shall be payable for total
ex-bus energy scheduled to be supplied to the
beneficiary during the calendar month, at the specified
energy charge rate.
• Total Energy Charge payable in a month:
Energy Charge Rate x Scheduled Energy (ex-bus)
57
Energy Charges- servicing the operational cost
CERC Tariff Regulation 2019-24
41. 58
• Computation of Variable Charges [Energy Charge Rate (ECR)]
ECR = {(SHRn – SFCn x CVSF) x LPPF / (CVPF }+ {SFCn x LPSFi} + {LCn x LPL}
x {100/(100 – AUXn)}
• We get back the cost of primary fuel cost, Secondary fuel cost, cost of Auxiliary
power consumption and Cost of Reagents (limestone)
ECR = Constant x Landed price of coal (Price is determined based on the GCV at mines)
As received GCV of coal (measured at wagon tippler / track hopper
from rakes)
• ECR for recovering primary fuel cost shall be payable for total ex-bus energy scheduled to be
supplied to the beneficiary during the calendar month, at the specified energy charge rate.
• Total Energy Charge payable in a month:
Energy Charge Rate x Scheduled Energy (ex-bus)
Effect of Constant depends on normative parameters
Heat Rate APC Specific Oil
58
Energy Charges- servicing the operational cost
CERC Tariff Regulation 2019-24
43. Sample calculation for 1 kCal/kWh HR saving
Capacity 500 MW
Annual Full load generation 4380 Mus
PLF 85 %
GCV of coal 3700 kCal/kg
Cost of coal 4 Rs./kg
Heat Rate 2250 kcal/kWh
Annual cost of generation at HR 2250 9055945946 Rs.
Annual cost of generation at HR 2249 9051921081 Rs.
Annual Savings 4024864.86 Rs.
44. S No Parameter Variation Effect on Boiler
efficiency (%)
Heat Rate deviation
(Kcal/Kwh)
1 Boiler Efficiency +1 % 1 -26
2 Oxygen +1% - 0.3 +7.8
3 FG Temp +1 Deg C -0.05 +1.3
4 Carbon in BA +1% - 0.2 + 5.2
5 Carbon in FA +1 % -0.8 + 20.8
6 Fuel moisture +1 % -0.175 +4.5
7 Hydrogen in fuel +0.1 % -0.15 +3.9
8 GCV of fuel +100 kcal/kg +0.2 -5.2
9 Ash in fuel +5 % -0.03 +0.8
10 Relative humidity +10 % -0.04 1.0
11 Ambient temp +10 Deg +0.14 -3.6
BOILER PERFORMANCE OPTIMISATION
45. EFFECT OF PARAMETER DEVIATION ON HEAT RATE
(210 MW)
Description Deviation
Change in
HR
Rs
Lakhs/year
Condenser Back Pressure 1mmhg 2 33.8
Flue gas Temp after RAPH 1 Deg C 1.3 21.97
Excess O2(%) 0.5% 3.3 55.77
MS Temp 1 Deg C 1.6 27.04
MS Pressure 1 ksc 1.8 30.42
HRH Temp 1 Deg C 0.68 11.492
RH Spray 1 TPH 0.53 8.957
SH Spay 1 TPH 0.04 0.676
Boiler Effi (%) 1% 26 439.4
HPT Efficiency 1% 4.5 76.05
IPT Efficiency 1% 4.5 76.05
46. UNIT CAPACITY ( MW ) 210 660
PLF % 85 85
Saving Target 0.1 0.1
ECR Rs/KWH 3.25 3.25
YEARLY GENERATION (MU)
CAPACITY
1839.6 5782
GENERATION (MU) 1563.66 4914
Saving of Aux Power
Consumption (MU)
1.56 4.914
SAVING POTENTIAL Rs
LAKHS PER YEAR
50.82 159.72
EFFECT OF DEVIATION OF AUXILIARY POWER CONSUMPTION
47. CERC is revising the norms based on actual performance of stations.
In future CERC may further tighten the norms.
Issues… Tightening of Norms
2001-04 2004-09 2009-14 2014-19 2019-24
O&M
expenses
Station
specific
norms with
6% escalation
9.36 Lac/MW
with 4%
escalation
13 Lac/MW
with 5.72%
escalation
16 Lac/MW
with 6.35%
escalation
22.51
Lac/MW with
escalation of
3.5%
Incentive Based on
Scheduled
PLF
Based on
Scheduled
PLF
Based on
Availability
Based on
Scheduled
PLF
Based on
Scheduled
PLF
Income Tax Pass through Pass through Grossed up
(Corporate
Tax)
Grossed up
(actual tax
rate)
Grossed up
(actual tax
rate)
48. CERC is revising the norms based on actual performance of stations.
In future CERC may further tighten the norms.
Issues… Tightening of Norms
2001-04 2004-09 2009-14 2014-19 2019-24
Heat Rate
(kCal/kWh)
(500 MW)
2500 2450 2425 2375
2390 (2430
for 200 MW)
Target
Availability
80 80 85 83 (85) 85
APC 8 7.5 6 5.25 5.75
SOC
(ml/kWh)
3.5 2 1 0.5 0.5
ROE (%) 16 14 15.5 15.5 15.5
49. 66
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