ࡱ> (*'G bjbjَ  ] 3Dnnnn.nn ""L(FPublic submissions to charge rules issue paper for irrigation infrastructure operators by D W Sehestedt 14/06/2008 Some comments with regard to the issue of charging by operators when an irrigator wishes to sell some or all of their water entitlements. Delivery entitlements that remaining on a landholding after a water entitlements has been transferred still attract an annual access fee. There should be some mechanism in place so that the access fee will not be increased from year to year above a certain amount. This maybe achieved by only CPI adjustment. Termination fees are determined by a multiple of the access fee. For an irrigator to transfer or trade their water entitlements they would want to have some certainty as to the ongoing access fee or termination fees. After transferring their water entitlements and not immediately terminating their delivery entitlements a irrigator several years later may find that they have no requirement for access to the operators system, and wish to terminate delivery entitlements. One important factor the irrigator would have to take into account is that the access fee in the intervening years has not significantly increased. This could happen if the operator chooses to move some of the variable costs across to the fixed charges. In years of full allocation the above-mentioned action would not disadvantage remaining irrigators but may have a significant effect on those irrigators now wishing to terminate their access to the system. Shadow access fees. Although non landholding account owners are entitled to view how an operator sets the shadow access fee it is generally beyond the scope of the irrigator to make such deliberations. The use of shadow access fees is a discrimination against those irrigators wishing to sell all or part of their water entitlements. Currently in the MIL irrigation system the annual access fee is approximately $9.50 and the termination fee is $385 a multiple of 40 times. This is certainly a deterrent for irrigators wishing to trade some or all of their water. Question 14. I refer you to attached documents headed Talking Water Tuesday 8th of April 2008. And attached documents Transfer Rules Policy. Question 15. A) I consider this to be a normal commercial risk that the operator should undertake. It's not much different than the supplier of electricity gas or telephone to a property. You may not use these services but still play the ongoing charges. d) Yes e) No g) No Question 16 b) I refer you to attached documents. Question 17. Unable to determine ?. Question 19. I refer you to previous comments earlier in this document. Question 21. In relation to shadow access fees they should be abandoned straightaway. In relation to termination fees these should be reduced to zero over eight years starting with 10 times the access fee. I would like to thank you for the opportunity of being able to comment on this issue. Regards Des Sehestedt. ZtCJZhst   GHop$ Ho  / =!"#$% [$@$NormalmH <A@<Default Paragraph Font.B`. Body Text$CJ     ^g% 0 :A " b n  D W SehestedtEC:\DOCUME~1\DWSEHE~1\LOCALS~1\Temp\AutoRecovery save of Document1.asd@ @GzTimes New Roman5Symbol3& zArial"qh_cƆm $20!  D W SehestedtOh+'0@    (08ssD W Sehestedto W Normaleorm1rmMicrosoft Word 8.0@$:@< ՜.+,D՜.+,, hp|   !    Title 6> _PID_GUIDAN{3FAB4339-4A7E-4435-B63E-85CF030373C6}  !"#$%&)Root Entry F@H"L+1TableWordDocumentSummaryInformation(DocumentSummaryInformation8CompObjj  FMicrosoft Word Document MSWordDocWord.Document.89q