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Getting Ready!. Potential issues for consumers Ergon Distribution Network Regulatory Proposal Bev Hughson, Consumer Challenge Panel (CCP) 2 September 2014
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Getting Ready! Potential issues for consumers Ergon Distribution Network Regulatory Proposal Bev Hughson, Consumer Challenge Panel (CCP) 2 September 2014 The data and charts in this presentation are based on the information provided by Ergon to the Australian Energy Regulator in its 2006-13 Economic Benchmarking Regulatory Information Notice (Consolidated), 30 April 2014, Public Version. The author cannot vouch for the accuracy of the information provided by Ergon in its Notice.
Agenda • Some background • Ergonis special! • The regulatory dance • Revenue trends • Capital requirements • The RAB • Demand forecasts • Growth, Replacement & Reliability capex • Operating costs (opex) • Return on capital (WACC) • Wrap up – some key questions to ask
A Regulatory Reset The things that matter • The total revenue that the AER allows Ergon • This is today’s topic • We are looking at history – to help us assess future • The way Ergon allocates this revenue in their prices – very important, but for another day • The way prices change across the 5 years • The big jump (up usually, down if your lucky) • Or smooth across the years • How Ergon engages with their customers in making these decisions
A warning: Ergon is a special case! • Non-Ergon regions (Qld SE, NSW, Vic, SA) • Most customers don’t see a network price in their bill • But the retail price will be influenced by the size & structure of the network tariff • For larger customers the network price is a ‘pass-through’ • Ergon is different • Most customers have the same retail price as Energex • What Ergon does is not of concern (except to Govt)? • However, larger customers (>100 MWh/year) do see Ergon’s network price • And, they are not all happy! • Tariff structures matter • Will the status quo change? • Importance of the very large high voltage (HV) customers
The regulatory dance • We have a “propose-respond” regulatory model • Important because it defines the roles of the networks & the AER (and consumers – more on this later) • Step 1: Ergon “proposes” to the AER • Revenue requirements, based on: • Forecast capital and operating expenditure, return on assets, depreciation, tax costs, incentive payments, tariff strategy • Step 2: The AER responds (“Draft Determination) • Yes, no, maybe yes if you fix up this and that • Step 3: Ergon amends their proposal • Step 4: The AER approves or rejects (“Final Determination”) • Step 5 (A): Ergon accepts, and publishes tariffs, or • Step 5(B): Ergon rejects and takes the issue to the Competition Tribunal • Where do consumers fit in? Where is the most impact? • Talking to Ergon before the proposal? • Making submissions after the proposal? • Responding to the AER’s Draft Determination? • Other? • Culture shock! Are all the players ready for a brave new world
Reading the Crystal Ball • Things we need to do before we start: • Learn from history • Forecast energy use • Forecast customer numbers • Forecast average use/customer • Forecast technology change • Forecast government policies • Forecast input prices (labour/materials) • Forecast the weather… • These forecasts will underpin revenue, tariffs, capex and opex • See later slides
Ergon’s revenue per customer accelerates – but not for all (truly strange!)
What determines the revenue allowance next reset? • Capital costs – now over 70% of costs • Opening regulatory asset base (RAB) • Plus capital investment (Capex) • Plus inflation adjustment • Minus depreciation • Closing RAB • Rate of Return on asset base • Operating Costs (Opex) • Tax allowance • Incentive scheme payments (+/-)
How much capital & for what return • Assess the regulatory asset base for each year • What is the capital expenditure (capex) each year? • Is it prudent and efficient? • Is it growth, replacement, or reliability capex? • Growth: Forecasts of energy demand, peak demand & customers • Replacement: Assess age & condition of network • Reliability: Assess service performance (time off supply etc) • What is the rate of return on asset base • Return on equity (shareholder) & • Return on debt • What is the credit rating of the DNSP? • What is the business risk profile? • Should government ownership make a difference?
Growth capex: What’s happening to demand? Ergon is only network where there is no big decline in residential volumes?
What’s behind the demand trends? Decline in residential use from 2009-10 is only 7.3%. Energex is 15.6%
Growth & replacement capexHow much more improvement required?
Reliability CapexAre there still performance issues? Energex average SAIDI is less than 100 minutes
Rate of Return (WACC) -a new approach? • Most networks seen very rapid price increases & currently very high profits – 2012-13 changes to Rules • Cost of Debt (60% WACC): • AER new approach - move to 10 year average of 10-year tenor bonds over a ten year transition period – disputed • Credit rating (BBB+), and data sources - disputed • Cost of Equity (40% WACC) • Cost of equity = [risk free rate + (MRP * beta)] - disputed • Risk free rate assessment (about 3.5% at this time) - disputed • Market Risk Premium (6.5%) - disputed • Equity beta (0.7) – disputed • Imputation Credits (adjust the tax cost allowance) –disputed
Cost of Capital – going down… (cost of debt*0.6)+(cost of equity*0.4) 2016-2020 Cost of Debt? Ergon’s reported weighted average cost of debt (12/13) is 7.31% 2010-2015 cost of debt Approx 8.98% 2016-2020 Input to Cost of Equity?
Cost of Equity Regulatory BenchmarksSource: AER Explanatory Statement RoR Guideline, Appendix C, p 32 NSW NSP’s proposing 10.1%; AER NSW Transitional Determination 8.9%
The bottom line & why you should care Forecast RAB & “Interest “rate figures are estimates – for illustration purposes only
Summary of Issues to Watch • Are the forecasts reasonable? • Is the capex prudent and efficient? • Is the opex prudent and efficient? • 2012/13 will be the base year for next period • Is the cost of capital reasonable given economic conditions? • Consistent with risk, and fair to consumers • Provide the right incentives for efficient investment • Efficiency schemes (opex and capex)? • A problem unless AER sets tight allowances • Witness NSW distribution companies… • Have consumers been adequately engaged in the decisions by the networks and the AER?