Application Martin No: gr9902 Jones Contents
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- Bu səhifədəki naviqasiya:
- Information provision and performance indicators Information provision Code requirements
- Figure 4.: Summary of Attachment A information
- Category 3: operations and maintenance costs
- Category 5: system capacity and volume assumptions
- Commission’s Draft Decision
- Submissions from interested parties
- Proposed amendment FDA4.1
- Key performance indicators Code requirements
- Figure 4.: Average Australian Pipeline Tariffs Service standards
- Table 4.: Service standards
- 1979/80 1984/85 1989/90 1994/95
- Table 4.: System use gas
- Total gas used (TJ) 986.409 1,033.692 1,333.238
- Total cost (financial accounts) $2,478,000 $2,602,000 $3,261,000
Review triggerIn relation to the issue of a trigger mechanism, the Commission notes that the proposal did not attract significant support from interested parties, some of whom expressed hostility to the concept. It appears that inserting a trigger mechanism into the access arrangement would not provide adequate certainty to users or potential users as to the tariffs that would apply if the access arrangement were opened under the trigger. As noted in section 3.1.6 of the Final Decision, it appears that the insertion of a review trigger would not meet the Commission’s intended objectives in this case. Accordingly, the Commission does not propose to require Epic to insert a trigger mechanism into the access arrangement nor to comply with the Draft Decision’s proposed amendment A3.36. In its Draft Decision at A3.36, the Commission required Epic to define specific major events that would trigger an obligation on the service provider to submit revisions prior to the revisions submission date. This contrasts with some Queensland pipelines which are being required to specify major events that would trigger a review of the non-tariff aspects of their access arrangement. This is because the derogated access arrangement period for these pipelines is significantly longer than usual - between 15 and 22 years. In contrast, the Roma to Brisbane pipeline has a derogated access arrange period of only 5 years. Information provision and performance indicators
The service provider’s access arrangement information must contain sufficient information in the opinion of the relevant regulator to:
According to section 2.7 of the Code, the access arrangement information provided may include any relevant information, but must at least contain the categories of information described in Attachment A to the Code, which is summarised in Figure 4. below. Figure 4.: Summary of Attachment A information The information required is divided into six categories:
Tariff determination methodology; cost allocation approach; and incentive structures. Category 2: capital costs Asset values and valuation methodology; depreciation and asset life; committed capital works and planned capital investment (including justification for); rates of return on equity and debt; and debt/equity ratio assumed. Category 3: operations and maintenance costs Fixed versus variable costs; cost of services by others; cost allocations, for example, between pricing zones, and cost categories. Category 4: overheads and marketing costs Costs at corporate level; allocation of costs between regulated and unregulated segments; cost allocations between pricing zones, services or categories of asset. Category 5: system capacity and volume assumptions Description of system capabilities; map of piping system; average and peak demand; existing and expected future volumes; system load profiles and customer numbers. Category 6: key performance indicators Indicators used to justify ‘reasonably incurred’ costs Under section 2.8 of the Code, information included in the access arrangement information may be categorised or aggregated. The extent to which it may be categorised or aggregated is that which is necessary to ensure that disclosure of the information is, in the opinion of the relevant regulator, not unduly harmful to the legitimate business interests of the service provider, a user or prospective user. If the relevant regulator is not satisfied that the access arrangement information meets the requirements of the Code, it may require the service provider to make changes to the access arrangement information. Likewise, if requested to do so by any person, the relevant regulator must review the adequacy of the access arrangement information. However, the relevant regulator must not require the inclusion of material the release of which, in the regulator’s opinion, could be unduly harmful to the legitimate business interests of the service provider or of a user or prospective user (section 2.9). If the relevant regulator requires the service provider to change the access arrangement information, it must specify the reasons for its decision and allow the service provider reasonable time to make the changes and to resubmit the access arrangement information. This chapter relates specifically to access arrangement information provided for users and prospective users. The regulator also has wider information-gathering powers under the GPAL. That Law gives the regulator power to require a person to give the regulator information or a copy of a document.485 The power can be exercised if the regulator has reason to believe that a person has information or a document that may assist the regulator in the performance of any of the regulator’s prescribed duties under the Law. Section 2.8 of the Code states that nothing in that section limits the regulator’s power under the Law to obtain information, including information in an uncategorised or unaggregated form. The Code and the Law place separate limitations on the regulator’s discretion to disclose information received that has been identified as being of a ‘confidential or commercially sensitive nature’.486 These statutory powers aside, the Commission values the co-operation of the service provider and other interested parties in making information available in response to the numerous queries that inevitably arise in considering complex matters. Epic’s proposal Epic submitted access arrangement information in conjunction with the access arrangement on 1 April 1999. The Commission has made both documents available on-line on the Commission’s website. A copy was provided to the Code Registrar and the documents have been available in hard copy in response to any requests by interested parties. Details were included, where appropriate, in the Commission’s Issues Paper of September 1999 and relevant extracts are reproduced in this Final Decision. Epic corrected some parts of the access arrangement information in later correspondence with the Commission. Following the release of the Draft Decision on 16 August 2000, Epic submitted a consolidated corrected version of the access arrangement. This was also made available on the Commission’s website.487 In response to the Draft Decision and submissions from interested parties, Epic Energy proposed several substantial amendments to its access arrangement. Given the significance of the proposed amendments, Epic submitted a revised access arrangement to the Commission on 17 May 2001 and a subsequent revised access arrangement version 29 June 2001. This is also available on the Commission’s website. Commission’s Draft Decision The Commission stated in the Draft Decision that there is sufficient information in the access arrangement information to enable users and prospective users to understand the derivation of the elements in the proposed access arrangement. There is also sufficient information to enable them to form an opinion as to the compliance of the access arrangement with the provisions of the Code. Furthermore, the access arrangement information includes the information described in Attachment A of the Code. Submissions from interested parties There were no submissions on this issue. Commission’s considerations The Commission is satisfied that there is sufficient information in the access arrangement information and the public domain to enable users and prospective users to understand the derivation of the elements in the original access arrangement. There is also sufficient information to enable them to form an opinion as to the compliance of the original access arrangement with the provisions of the Code. However, changes set out in Epic’s revised access arrangement (version 29 June 2001) and specified in this Final Decision will result in a need for further revisions to the access arrangement information. In particular, the AAI will need to be updated to account for the expansion of the pipeline system undertaken for Pelican Point Power and to account for revisions to the term of the access arrangement. The Commission therefore requires Epic to comply with proposed amendment FDA4.1. Proposed amendment FDA4.1 For the access arrangement to be approved, the Commission requires Epic to revise the access arrangement information so that it is consistent with the latest revised access arrangement (version 29 June 2001) and the amendments specified in this Final Decision. Key performance indicators
Category 6 of Attachment A to the Code includes key performance indicators (KPIs) in the ambit of access arrangement information. The KPIs given as examples are:
Section 8.6 of the Code allows the regulator to ‘have regard to any financial and operational performance indicators it considers relevant in order to determine the level of costs within the range of feasible outcomes under section 8.4 that is most consistent with the objectives contained in section 8.1’. The regulator must then identify the indicators and provide an explanation of how they have been taken into account (section 8.7 of the Code). Epic’s proposal Epic suggested that there are two distinct potential roles for KPIs and benchmarks:
Epic submitted that there are no useful comparators in Australia at this time, and therefore did not seek to use KPI data in setting or justifying the proposed reference tariffs.488 Epic submitted that there are too many differences of a geographic, historic, political, operational and physical nature in the Australian pipeline sector, to permit benchmarks to be used to set the level of allowable costs. Rather, Epic put the view that quality of service indicators may provide some future comparison of the service performance of pipelines in Australia.489 Further, Epic submitted that Category 6 of Attachment A to the Code should be modified to enable pipelines to develop quality of service standards and supporting measurement data.490 Despite Epic’s view that KPIs are of limited use, Epic did provide a simplified comparison of gas haulage charges in 1997 across a range of transmission pipelines in Australia. Epic noted that, despite its pipeline being fully compressed, it still held a very competitive position.491 Figure 4.: Average Australian Pipeline Tariffs 
Service standards Epic submitted that service factors are more relevant when comparing key performance indicators across a range of pipelines. Table 4. compares Epic’s performance with that of PASA, its predecessor as owner and operator of the MAPS. Table 4.: Service standards
Source: MAPS access arrangement information, p. 16. Notes:
Epic also provided the following information relating to its historical use of gas in operations. This shows a decline in unaccounted-for gas (UAG) between 1996 and 1998. Table 4.: System use gas
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