Application Martin No: gr9902 Jones Contents

‘Welcome to bull country’, The Economist, 18 July 1998, pp. 17-19.

78 ACCC, Draft Statement of Principles for the Regulation of Transmission Revenues, 27 May 1999, p. 79.

79 For example, see Tro Kortian, Australian Sharemarket Valuation and the Equity Premium, September 1998.

80 Epic response to Draft Decision – Part A, Appendix 3, 10 October 2000, p. 5.

81 Ibid.

82 Standard and Poor’s Rating Methodology for Global Power Companies, 1999, p. 4.

83 Modigliani and Miller establish that the value of the company is unaffected by its choice of capital structure using the principle of ‘no arbitrage’. This principle states that assets that offer the same cash flows must sell for the same price. Thus, a company’s borrowing decision does not affect either the expected return on the company’s assets or the required return on those assets.

84 Epic response to Draft Decision, 10 October 2000, p. 11.

85 Lally, Response to 2001 Electricity Distribution Price Review Draft Decision, 17 July 2000, p. 2.

86 Ibid, p. 3.

87 ACCC, Draft Statement of Principles for the Regulation of Transmission Revenues, May 1999, p. 82.

88 ACCC, Draft Statement of Principles for the Regulation of Transmission Revenues, 27 May 1999, p. 79.

89 See page 60 of the ORG’s 2003 Review of Gas Access Arrangements, Consultation Paper No 1

90 Epic response to Draft Decision, 10 October 2000, part A, p. 11.

91 Access Arrangement Information, p. 31.

92 Epic response to Draft Decision, 10 October 2000, part A, p.12.

93 Professor Davis, Report on Asset and Debt Beta for MAPS, 20 August 2001, p.2.

94 Envestra Limited, Access Arrangement Information for the South Australian Distribution System, 22 February 1999, Appendix B, p. 4^.

95 Professor Davis, The Weighted Average Cost of Capital for Access Arrangements for Envestra – A Report prepared for the SAIPAR, 20 October 1999, p. 7^.

96 Ibid, p. 7.

97 Epic, Response to Draft Decision – Part A, 10 October 2000, p. 10.

98 Professor Davis, Report on Asset and Debt Beta for MAPS, 20 August 2001, p.2.

99 See ACCC, Draft Decision Access Arrangement proposed by NT Gas Pty Ltd for the Amadeus Basin to Darwin Pipeline, p. 2 May 2001.

100 The Age, p. 4, Origin confirms big Otway gas discovery, 24 May 2001.

101 Herald Sun, p. 27, Esso, BHP eye gas link, 22 May 2001.

102 The Advertiser, p. 2, Timor Sea to Provide More Gas, 9 May 2001

103 See Submission by Energy SA of 29 June 2001 concerning MAPS

104 See Submission by TXU Trading of 21 May 2001 concerning MAPS

105 The Brattle Group, The Cost of Capital for the Dampier to Bunbury Natural Gas Pipeline, October 1999

106 Epic response to Draft Decision, 10 October 2000, Part A, p. 13.

107 Ibid, p. 13.

108 Ibid, p. 14.

109 ORG, Electricity Distribution Price Determination 2001-2005, Vol 1, p. 280.

110 Professor Davis, Report on Asset and Debt Beta for MAPS, 20 August 2001, p.2.

111 Equity betas were provided by Bloomberg (US,UK, Aust), Ibbotson (US), the London Business School (UK) and the Australian Graduate School of Management Risk Measurement Service(Aust).

112 Figures are for electricity transmission and distribution.

113 Figures are for electricity distribution.

114 The location of the averages within these ranges is dependent upon which adjustment (eg. Blume, Vasicek) was considered appropriate. For a detailed discussion of these adjustments, see ORG’s Electricity Distribution Price Determination 2001-2005, Vol 1, pp. 275-9.

115 NERA, International Comparison of Utilities’ Regulated Post Tax Rates of Return in: North America, the UK and Australia, March 2001, p.19.

116 Professor Davis, Report on Asset and Debt Beta for MAPS, 20 August 2001, p.3.

117 Data from the Australian context is limited, however the Commission notes the asset betas of the few relevant publicly listed Australian companies: Alinta Gas (0.30), APT (0.38), Envestra (0.10) and United Energy (0.53). Asset betas were derived from equity betas and gearing ratios using the formula: Ba = Be (1-D/V). The capital structure of Envestra involves stapled securities with equity and debt characteristics which may make these securities unreliable with respect to information on the underlying equity beta. Sourced from Centre for Research in Finance, AGSM Limited, via Commonwealth Securities on 28 August 2001.

118 As stated in Professor Davis’ Report on Asset and Debt Beta for MAPS, 20 August 2001, it should be noted that the debt beta and the equity beta will be inversely related as they involve a division of the underlying asset beta. Thus if a higher debt beta is proposed, there should be some (marginal) reduction in the equity beta resulting from the levering-delevering formula used to convert asset betas into equity betas).

119 Professor Davis, Report on Asset and Debt Beta for MAPS, 20 August 2001, p.3.

120 While these amounts have been applied to the revenue model, they have been referred to in rounded terms (7.1 and 12.6 per cent respectively) elsewhere in this Final Decision.

121 Code section 8.4(a).

122 Access arrangement information, p. 13.

123 Access arrangement information, p. 13.

124 Refer Epic letter to customers, 1 December 1999.

125 In the interests of comparison between pipeline systems, the ORC figure may be used as a measure of the value of the capital assets employed.

126 TGT submission, 26 October 1999.

127 TGT submission, September 2000, p. 5.

128 Origin submission, 21 September 2000, p. 24.

129 Ibid, p. 25.

130 Epic response to Draft Decision, Part C, p. 5.

131 Ibid, p. 5.

132 Access arrangement information, p. 10.

133 Access arrangement information, p. 10.

134 Access arrangement information, p. 12.

135 ACCC, Price Exploitation and the New Tax System, March 2000.

136 Epic, Response to Draft Decision, part A, p. 14.

137 A detailed discussion of the ‘s-bend’ problem is provided in Attachment B to ACCC, ‘NSW and ACT Transmission Network Revenue Caps 1999/00-2003/04’, Final Decision January 2000, and Attachment C to ACCC, ‘Access Arrangement by AGC, Pipelines (NSW) Pty Ltd for the Central West Pipeline, Final Decision, June 2000.

138 Equal to the difference between the nominal vanilla WACC and the nominal pre-tax WACC that has been derived from the Commission’s cash flow analysis.

139 Epic Energy response to Submissions Made on the Access Arrangement for MAPS, 1 February 2000.

140 Epic, proposed access arrangement lodgement of 29 June 2001, clause 5.2(a)(viii)(A).

141 ACCC, Draft Decision, Access Arrangement proposed by Epic Energy South Australia Pty Ltd for the Moomba to Adelaide Pipeline System, 16 August 2000, p. 87.

142 TGT submission, September 2000, p. 6.

143 Origin, Response to ACCC Draft Decision in respect of the access arrangement for the Moomba-Adelaide Pipeline, 21 September 2000, pp. 8-9.

144 WMC submission, 25 August 2000, p. 2.

145 Ibid, p. 2.

146 Ibid, p. 2.

SA Government submission, 8 September 2000, p. 9.

147 Ibid, p. 11.

148 SA Government submission, 8 September 2000, p. 11.

149 SA Department of Industry and Trade submission, 13 November 2000, p.2.

150 Ibid, p. 1.

151 Transcript of proceedings, ACCC pre-decision consultation forum – MAPS access arrangement, p.22.

152 Transcript of proceedings, ACCC pre-decision consultation forum – MAPS access arrangement, p.21.

153 Ibid, p.24.

154 Ibid, p.25.

155 Transcript of proceedings, ACCC pre-decision consultation forum – MAPS access arrangement, p.25.

156 Epic, Response to ACCC Draft Decision, Part A, p.15.

157 Email to Commission from Epic of 8 April 2001

158 See discussion in section 3.1.5.

159 SAGEUG Submission, 12 September 2000, p. 1.

160 Epic, Response to ACCC Draft Decision, Part A, p. 15.

161 NRG Flinders Submission on Epic’s 17 May 2001 Revised Access Arrangement, 2 July 2001, p.1.

162 TGT Response to ACCC Issues Paper on Epic’s 17 May 2001 Access Arrangement, 2 July 2001, p.2

163 Epic, Revised Access Arrangement, 29 June 2001, clause 1.3.

164 Natural Gas Pipelines Access Act 1995 (SA), Part 6.

165 Epic, consolidated response to Commission’s letter of 30 April 1999, p. 10.

166 TGT submission, 26 October 1999, p. 29.

167 Epic, response to submissions, 1 February 2000, p. 27.

168 Epic, response to submissions, 1 February 2000, p. 27.

169 Access arrangement information, p. 10.

170 N.T. Gas Pty. Limited, Access Arrangement Information for the Amadeus Basis to Darwin Pipeline, 25 June 1999, p. 6.

171 Epic, Information Brochure and Access Principles for the Moomba-Adelaide Pipeline System, June 1998.

172 Access arrangement information, p. 4.

173 TGT submission 18 September 2000, p. 5.

174 Origin submission 21 September 2000, p. 8 at 3.4.5.

175 OEP submission 31 October 2000, p. 5 at (5).

176 Origin submission 21 September 2000, p. 5 at 3.1.2.

177 TGT submission 18 September 2000, p. 4 at (i).

178 Origin submission 21 September 2000, p. 6 at 3.2.1.

179 Origin submission 21 September 2000, p. 6 at 3.2.2.

180 Origin submission 21 September 2000, p. 8 at 3.5.1.

181 Santos submission 18 September 2000, p. 1 at (1).

182 Santos submission 18 September 2000, p. 1 at (1).

183 AGLES&M submission 29 June 2001.

184 AGLES&M submission 29 June 2001.

185 Origin submission 21 September 2000, p. 9 at 4.1.5.

Origin submission 12 July 2001, pp. 2-4.

186 OEP submission 31 October 2000 on C2000/269, p. 3.

187 Origin submission 21 September 2000, pp. 9-11.

188 TGT submission September 2000, pp. 5-6.

189 Origin submission 21 September 2000, p.12 at 5.4.2.

190 Origin submission 21 September 2000, p. 36 at 21.1.1.

191 WMC Limited submission 25 August 2000, p. 2 at (2).

192 TGT submission 2 July 2001, p. 4 at (3).

193 NRG Flinders submission 29 June 2001, p. 2 at (2).

194 Potential Energy submission 29 June 2001, p. 2.

195 OEP submission on CR99/53 and GR9902, 31 October 2000, p. 3 at (3).

196 DIT submission 13 November 2000, pp 1-2.

197 AGLES&M submission 29 June 2001.

198 DIT submission 13 November 2000, pp 1-2.

199 TGT submission 2 July 2001, p. 4 at (3).

200 NRG Flinders submission 29 June 2001, p. 2 at (2).

201 Potential Energy submission 29 June 2001, p. 2.

202 Potential Energy submission 29 June 2001, p. 2.

203 Potential Energy submission 29 June 2001, p. 2.

204 Potential Energy submission 29 June 2001, p. 3.

205 TGT submission September 2000, p. 7.

AGL submission 12 September 2000, Attachment.

206 AGLES&M submission 29 June 2001, pp. 3-4.

207 Minister for Minerals and Energy South Australia submission 8 September 2000, p. 1.

208 Origin submission 21 September 2000, p. 5 at 3.1.3.

209 Origin submission 21 September 2000, p. 7 at 3.3.1.

210 Epic submission 10 October 2000 Part C, p. 3.

211 Epic submission 10 October 2000 Part C, p. 4.

212 Epic response to submissions, 1 February 2000, p. 8. and Epic submission 10 October 2000 Part C, p. 3.

213 Epic submission 10 October 2000 Part C, p. 3.

214 Epic’s response to Origin’s submission 31 October 2000, p. 1 at 3.1.

215 Epic’s response to Origin’s submission 31 October 2000, p. 2 at 3.1.

216 Epic’s response to Origin’s submission 31 October 2000, p. 2 at 3.1.

217 Epic submission 10 October 2000 Part C, p. 3.

218 Epic’s response to Origin’s submission 31 October 2000, p. 2 at 3.2.

219 Epic’s response to Origin’s submission 31 October 2000, p. 2 at 4.1.

220 Epic’s response to Origin’s submission 31 October 2000, p. 3 at 4.2.

221 Epic’s response to Origin’s submission 31 October 2000, p. 3 at 4.2.

222 Epic’s response to Origin’s submission 31 October 2000, p. 3 at 5.1.

223 Epic’s response to Origin’s submission 31 October 2000, p. 3 at 5.2.

224 Epic’s response to Origin’s submission 31 October 2000, p. 4 at 5.4.

225 Epic submission 29 June 2001 at 3.2.

226 Epic submission 29 June 2001 at 3.3.

227 Epic submission 29 June 2001 at 3.3.

228 Epic submission 29 June 2001 at 3.3.

229 Epic submission 11 October 2000 Part C, p. 10.

230 Epic submission 11 October 2000 Part C, p. 10.

231 Epic submission 11 October 2000 Part C, p. 10.

232 Epic submission 11 October 2000 Part C, p. 10.

233 Epic submission 11 October 2000 Part C, p. 10.

234 Epic submission 11 October 2000 Part C, p. 3. Also see Response of Epic Energy to the submissions made on the access arrangement for the Moomba to Adelaide pipeline, 1 February 2000, p. 8.

235 Epic final decision submission #1, 23 August 2001, p. 5.

236 Origin submission 21 September 2000, p. 5 at 3.1.

237 Origin submission 21 September 2001, p. 6 at 3.2

238 Epic final decision submission #1, 23 August 2001, p. 7.

239 See Bowen CJ in the Tillmans Butcheries case.

240 Epic submission 29 June 2001 at 3.3.

241 Epic submission 29 June 2001 at 3.3.

242 Potential Energy submission 29 June 2001 at 3.

243 Epic submission 11 October 2000 Part A, p. 18.

244 Epic submission 11 October 2000 Part A, p. 18.

245 Epic submission 11 October 2000 Part A, p. 18.

246 Epic submission 11 October 2000 Part A, p. 19.

247 Epic submission 11 October 2000 Part A, p. 19.

248 Epic submission 11 October 2000 Part A, p. 19.

249 Epic submission 11 October 2000 Part A, p. 19.

250 Epic submission 11 October 2000 Part A, p. 19.

251 Epic submission 11 October 2000 Part A, p. 19.

252 Epic final decision submission #1, 23 August 2001, p. 6, 7.

253 Epic submission 11 October 2000 Part A, p. 18.

254 Epic’s response to Origin’s submission 31 October 2000, p. 1.

255 Origin letter on MAPS access arrangement 11 July 2001, p. 2.

256 Origin letter on MAPS access arrangement 11 July 2001, p. 2.

257 Origin submission 21 September 2000, p. 16 at 9.1.1.

258 Origin submission 21 September 2000, p. 16 at 9.1.2.

259 Origin submission 21 September 2000, p. 16 at 9.1.5, 9.1.6.

260 Epic’s response to Origin’s submission 31 October 2000, p. 5 at 9.1.

261 Epic letter 24 August 2001, p. 8.

262 Origin submission 21 September 2000, p. 16 at 9.1.5.

263 Epic’s response to Origin’s submission 31 October 2000, p. 5 at 9.1.

264 Epic letter 24 August 2001, p. 9.

265 Energy South Australia submission 29 June 2001, p. 3.

266 Energy South Australia submission 29 June 2001, p. 3.

267 AGL submission 29 August 2000 Attachment.

268 AGL submission 29 August 2000 Attachment.

269 AGLES&M submission 29 June 2001, p. 2.

270 NRG Flinders submission 29 June 2001 at 1.3.

271 Origin submission 6 July 2001, p. 2 at 1(iii).

272 Epic Part A response to ACCC Draft Decision, 10 October 2000, p. 20.

273 Origin submission 21 September 2000, p. 18 at 11.1.

274 Origin submission 21 September 2000, p. 18 at 11.1.2.

275 Epic’s response to Origin’s submission 31 October 2000, p. 5-6 at 11.1.

276 Origin submission 21 September 2000, p. 18 at 11.2.1.

277 Origin submission 21 September 2000, p. 18 at 11.2

278 Epic’s response to Origin’s submission 31 October 2000, p. 5-6 at 11.2.

279 Origin submission 21 September 2000, p. 18 at 11.3.1.

280 Epic’s response to Origin’s submission 31 October 2000, p. 5-6 at 11.3.

281 Origin submission 21 September 2000, p. 18 at 11.4.1.

282 Origin submission 21 September 2000, p. 18 at 11.4.1.

283 Origin submission 21 September 2000, p. 18 at 11.4.1.

284 Origin submission 21 September 2000, p. 19 at 11.4.1.

285 Epic’s response to Origin’s submission 31 October 2000, p. 6 at 11.4.

286 Origin submission 21 September 2000, p. 19 at 11.5.2.

287 Origin submission 21 September 2000, p. 19 at 11.5.3.

288 Origin submission 21 September 2000, pp. 19-20 at 11.6.1.

th Origin submission 21 September 2000, p. 18 at 11.4.2.

289 Origin submission 21 September 2000, p. 18 at 11.4.2.

290 Origin submission 21 September 2000, p. 19 at 11.5.1.

291 Origin submission 21 September 2000, p. 19 at 11.5.1.

292 Origin submission 21 September 2000, p. 19 at 11.5.1.

293 Origin submission 21 September 2000, p. 20 at 11.6.1.

294 Epic’s response to Origin’s submission 31 October 2000, p 7 at 11.6.

295 Epic’s response to Origin’s submission 31 October 2000, pp 6-7 at 11.5.

296 Epic’s response to Origin’s submission 31 October 2000, pp 6-7 at 11.5.

297 Origin submission 21 September 2000, p. 20 at 11.7.1.

298 Origin submission 21 September 2000, p. 20 at 11.7.1.

299 Epic’s response to Origin’s submission 31 October 2000, p 7 at 11.7.

300 Origin submission 21 September 2000, p. 21 at 11.8.1.

301 Epic’s response to Origin’s submission 31 October 2000, p 7 at 11.8.

302 OEP submission 31 October 2000, p. 12.

303 OEP submission 31 October 2000, p. 12.

304 Epic submission 16 August 2000 Part A, p. 21.

305 Origin submission 21 September 2000 p. 21 at 12.1.1.

306 AGL submission 12 September 2000 Attachment

307 Epic’s response to Origin’s submission 31 October 2000, p 7 at 12.1.

308 OEP submission re C2000/269 October 2000 at 12.

309 OEP submission re C2000/269 October 2000 at 12.

310 Energy SA submission 29 June 2001, p. 5.

311 Energy SA submission 29 June 2001, p. 5.

312 Santos submission 18 September 2000, p. 5.

313 Origin submission 21 September 2000, pp. 22-24.

314 Epic’s response to Origin’s submission 31 October 2000, p. 9 at 14.6.

315 Epic submission 11 October 2000 Part C, p. 8.

316 Epic submission 11 October 2000 Part C, p. 8.

317 Epic submission 11 October 2000 Part C, p. 8.

318 Epic letter 24 August 2001, pp. 2-3.

319 Origin submission 21 September 2000, p. 25 at 15.1.2.

320 Origin submission 21 September 2000, pp. 24-25 at 15.4.3.

321 Epic submission 11 October 2000 Part C, p. 5.

322 Epic submission 11 October 2000 Part C, p. 5.

323 Epic submission 11 October 2000 Part C, p. 5.

324 Epic’s response to Origin’s submission 31 October 2000, p. 9 at 15.1.

325 Epic’s response to Origin’s submission 31 October 2000, pp 9-10 at 15.2.

326 Epic submission 11 October 2000 Part A, pp 22-23.

327 Epic submission 11 October 2000 Part A, pp 22-23.

328 AGLES&M submission, 29 June 2001, p. 5.

329 AGLES&M submission, 29 June 2001, p. 5.

330 AGLES&M submission, 29 June 2001, p. 5.

331 Origin submission 21 September 2000, p. 27 at 16.1.1.

332 Origin submission 21 September 2000, p. 27 at 16.1.2.

333 Origin submission 21 September 2000, p. 27 at 16.1.6.

334 AGLES&M submission, 29 June 2001, p. 5.

335 AGLES&M submission, 29 June 2001, p. 5.

336 AGLES&M submission, 29 June 2001, p. 5.

337 AGLES&M submission, 29 June 2001, p. 5.

338 Origin submission 21 September 2000, p. 28 at 16.2.1.

339 Origin submission 21 September 2000, p. 28 at 16.2.1.

340 Origin submission 21 September 2000, p. 28 at 16.2.1.

341 AGLES&M submission, 29 June 2001, p. 5.

342 AGLES&M submission, 29 June 2001, p. 6.

343 Potential Energy submission 29 June 2001, p. 2.

344 Origin submission 21 September 2000, p. 28 at 16.4.2.

345 Origin submission 21 September 2000, p. 28 at 16.4.2.

346 Origin submission 21 September 2000, p. 28 at 16.4.2.

347 Origin submission 21 September 2000, p. 28 at 16.4.2.

348 Origin submission 21 September 2000, p. 29 at 16.4.3.

349 AGLES&M submission 29 June 2001, p. 6.

350 Origin submission 21 September 2000, p. 29 at 16.4.4.

351 Origin submission 21 September 2000, p. 29 at 16.4.4.

352 Epic’s response to Origin’s submission 31 October 2000, p. 10 at 16.1.

353 Epic letter 29 August 2001, p. 4.

354 Epic submission 11 October 2000 Part C, p. 6.

355 Epic submission 11 October 2000 Part C, p. 6.

356 Epic’s response to Origin’s submission 31 October 2000, p. 11 at 16.4.

357 Epic’s response to Origin’s submission 31 October 2000, p. 11 at 16.4.

358 Epic letter 24 August 2001, p. 13.

359 OEP submission 31 October 2000, p. 13.

360 Osborne submission 7 October 1999, p. 3.

361 Osborne submission 7 October 1999, p. 3.

362 Osborne submission 7 October 1999, p. 3.

363 Origin submission 21 September 2000, p. 30 at 17.3.

364 Origin submission 21 September 2000, p. 30 at 17.3.2.

365 Origin submission 21 September 2000, p. 31 at 17.4.1.

366 Origin submission 21 September 2000, p. 31 at 17.4.2.

367 Origin submission 21 September 2000, p. 32 at 17.4.3.

368 Origin submission 21 September 2000, p. 32 at 17.5.3.

369 Origin submission 21 September 2000, p.33

370 Origin submission 21 September 2000, p. 34 at 17.7.1.

371 Origin submission 21 September 2000, p. 34.

372 Epic’s response to Origin’s submission 31 October 2000, pp. 11-13.

373 Epic submission 31 October 2000, p. 13.

374 Epic letter 29 August 2001, p. 4.

375 Epic letter 29 August 2001, p. 5.

376 Epic letter 29 August 2001, p. 5.

377 Epic’s response to Origin’s submission 31 October 2000, p. 12 at 17.3.

378 Epic’s response to Origin’s submissions, p. 13.

379 Origin submission 21 September 2000, p. 24 at 16.1.5.

380 Origin submission 21 September 2000, p. 35 at 18.1.

381 Osborne submission 7 October 1999, p. 3.

382 Osborne submission 7 October 1999, p. 3.

383 Epic submission 10 October 2000 Part A, p. 23 at A3.17.

384 Origin submission 21 September 2000, p. 35.

385 Origin submission 21 September 2000, p. 35.

386 Epic’s response to Origin’s submission 31 October 2000, p. 13 at 19.1.

387 Epic’s response to Origin’s submission 31 October 2000, p. 13 at 19.1.

388 Origin submission 21 September 2000, p. 35 at 20.1.1.

389 Origin submission 21 September 2000, p. 35 at 20.2.

390 Origin submission 21 September 2000, p. 35 at 20.3, 20.3.1.

391 Origin submission 21 September 2000, p. 36.

392 Origin submission 21 September 2000, p. 36 at 20.4, 20.4.2.

393 Origin submission 21 September 2000, p. 36 at 20.4, 20.4.1.

394 Origin submission 21 September 2000, p. 36 at 20.4, 20.4.1.

395 OEP submission 31 October 2000, p. 13.

396 OEP submission 31 October 2000, p. 13.

397 Epic’s response to Origin’s submission 31 October 2000, p. 13 at 20.1.

398 Epic’s response to Origin’s submission 31 October 2000, p. 13 at 20.1.

399 Epic’s response to Origin’s submission 31 October 2000, p. 14 at 20.2.

400 Epic letter 24 August 2001, p. 18.

401 Origin submission 21 September 2000, p. 36 at 21.1.1.

Origin submission, 21 September 2000, p 36 – 39.

402 Epic’s response to Origin’s submission, 31 October 2001, p 14 – 15.

403 Origin submission 21 September 2000, p. 41.

404 Origin submission 21 September 2000, p. 41.

405 Origin submission, 21 September 2000, 41 – 43.

406 Epic’s response to Origin’s submission, 31 October 2000, p. 17.

407 Epic submission, 10 October 2000, p 25.

408 Origin submission 11 July 2001, p. 9.

409 Origin submission 21 September 2000, p. 43.

410 Origin submission 21 September 2000, p. 44.

411 TGT submission 2 July 2001, p. 2; NRG Flinders submission 29 June 2001, p. 1; AGLES&M submission, p. 2; Energy SA submission 29 June 2001, p. 4.

412 Origin submission 11 July 2001, p. 11.

413 Energy SA submission 29 June 2001, p. 4.

414 AGLES&M submission 29 June 2001, p. 2.

415 Origin submission 21 September 2000, p. 44.

416 Origin submission 21 September 2000, pp. 44-5.

417 Origin submission 21 September 2000, pp. 45-6.

418 Epic’s response to Origin’s submission, 31 October 2000, p 19.

419 Origin submission 21 September 2000, p. 46.

420 Origin submission 21 September 2000, p. 45.

421 Santos submission 18 September 2000, p. 3.

422 Epic response to Origin’s submission 31 October 2000, p. 19.

423 Epic letter, 24 August 2001, p 22.

424 Origin submission 21 September 2000, p. 46.

425 Origin submission 21 September 2000, p. 47.

426 Origin submission 21 September 2000, p. 48.

427 Origin submission 21 September 2000, p. 48.

428 Origin submission 21 September 2000, p. 48.

429 Origin submission 11 July 2001, p. 10.

430 Epic response to submissions 1 February 2000, p. 1 at 1.1.

431 Origin submission 21 September 2000, p 40.

432 Origin submission 21 September 2000, pp. 40-41 at 24.2.4.

433 Epic’s response to Origin’s submission 31 October 2000, p. 16 at 24.1.

434 Epic submission 11 October 2000 Part A, p. 17.

435 For example, reference tariffs may remain unchanged, but a surcharge may be levied on incremental users.

436 Epic letter, 29 August 2001, p.5.

437 Origin submission, 11 July 2001, p 6, TGT submission, July 2001, p 2, NRG Flinders submission, 29 June 2001, p 1, and Santos submission, 10 July 2001, p 2.

438 TGT submission, July 2001, p 2 and NRG Flinders submission, 29 June 2001, p 2.

439 Santos submission, 10 July 2001, p 2.

440 TGT submission, July 2000, p 3 and Potential Energy submission, 29 June 201, p 2.

441 NRG Flinders submission, 29 June 2001, p 2 and Potential Energy submission, 29 June 201, p 2.

442 Potential Energy submission, 29 June 201, p 2 and TGT submission, July 2000, p 3.

443 Energy SA submission, 29 June 2001, pp. 2-3.

444 Potential Energy submission, 29 June 201, p 2.

445 AGLES&M submission, 29 June 2001, p 1.

446 TGT submission, July 2001, p 3 and Origin submission, 11 July 2001, p 3.

447 TGT submission, July 2001, p3.

448 Potential Energy submission, 29 June 2001, p 2 and TGT submission, 26 October 1999, p. 3.

449 Energy SA submission, 29 June 2001, p 3.

450 AGLES&M submission, 29 June 2001, p 2.

451 Santos submission, 19 July 2001, p 1.

452 Origin submission, 11 July 2001, p 3.

453 Epic letter 29 August, 2001.

454 Energy SA submission, 29 June 2001, p 1 and TXU submission, 21 May 2001, p 1-6.

455 Potential Energy submission, 29 June 2001, p 1.

456 NRG Flinders submission, 29 June 2001, p 1.

457 TGT submission, July 2001, p 2.

458 Origin submission, 11 July 2001, p 6.

459 TXU submission, 17 August 2001, p 1 – 3, Energy SA submission, 8 August 2001, p 1 – 2, ANP submission, 7 August 2001, p 1- 2, AGLES&M submission, 8 August 2001, p 1 – 2, and NRG Flinders, telephone conversation with Commission staff on 14 August 2001.

460 TXU submission, 17 August 2001, p 1.

461 Origin submission, 16 August 2001, p 2.

462 TXU submission, 17 August 2001, p 2, Energy SA submission, 8 August 2001, p 1, ANP submission, 7 August 2001, p 2, AGLES&M submission, 8 August 2001, p 1.

463 ANP submission, 7 August 2001, p 1.

464 TXU submission, 17 August 2001, p 2.

465 AGLES&M submission, 8 August 2001, p 1 and Energy SA submission, 8 August 2001, p 1.

466 TXU submission, 17 August 2001, p 2.

467 ANP submission, 7 August 2001, p 1.

468 Energy SA submission, 8 August 2001, p 1.

469 TGT submission, 13 August 2001, p 1.

470 TXU submission, 17 August 2001, p 2.

TXU submission, 17 August 2001, p 2.

471 TXU submission, 17 August 2001, p 3.

472 TXU submission, 17 August 2001, p 3.

473 AGLES&M submission, 8 August 2001, p 2.

474 Origin submission, 16 August 2001, p 3.

475 Epic letter, 29 August 2001, Attachment 1, p 1 – 5.

476 Origin Energy letter, 7 september 2001 and Pelican Point Power letter, 6 September 2001.

477 ACCC, Victorian Gas Transmission Access Arrangements Final Decision, p 137.

478 Origin submission 21 September 2000, p. 4 at 2.1.2.

479 Origin submission 21 September 2000, p. 4 at 2.1.3.

480 Origin submission 21 September 2000, p. 5 at 2.1.4.

481 Origin submission 21 September 2000, p. 4 at 2.1.

482 Origin submission 21 September 2000, p. 4 at 2.1.1.

483 Epic’s response to Origin’s submission 31 October 2000, p. 1 at 2.1.

484 TGT response to issues paper on revised access arrangement, July 2001, p. 5.

485 Gas Pipelines Access (South Australia) Law, section 41.

486 Code, sections 7.11 and 7.12 and Gas Pipelines Access (South Australia) Law, section 42.

487 This document was lodged on 29 August 2000 and largely represents Epic’s position prior to the Draft Decision document.

488 Access arrangement information, p. 14.

489 Access arrangement information, p. 15.

490 Access arrangement information, p. 15.

491 Access arrangement information, p. 16.

492 ACCC, Draft Statement of Principles for the Regulation of Transmission Revenues, 27 May 1999, p. 98.

493 ACCC, ‘Regulation of Transmission Revenues’, Issues Paper, May 1998.

494 In the interests of comparison between pipeline systems, the ORC figure may be used as a measure of the value of the capital assets employed.

495 ACCC, Statement of Principles for the Regulation of Transmission Revenues, 27 May 1999, p. 107.

496 In previous decisions, the Commission has utilised benchmark data published by reputable credit rating agencies, such as Standard and Poors.