ࡱ> %` |wbjbj ̟̟|o4QQQQlQ|ωRRRRRSSSNPPPPPP$hBteVS"SeVeVtRRSXXXeVNRRNXeVNXXzXRxR 1vQW҄(N0ωEeXREPES}T^XTL'U>SSSttXSSSωeVeVeVeV$33$h0 PUBLIC SUBMISSION ON THE TERMINATION FEE SECTION OF THE CHARGE RULES ISSUES PAPER FOR IRRIGATION INFRASTRUCTURE OPERATORS MURRUMBIDGEE IRIGATION LTD 15 July 2008 General Comments Since before the introduction of the Federal Water Act, private irrigation corporations in NSW and South Australia have maintained that the ԭ has no role in regulating the process and quantum of price setting inside these businesses. The ԭ acknowledges in this report that the natural checks and balances created by our structure, where customers are typically shareholders, reduces the incentive to maximise monopoly profits. Given the sorts of advances that have been achieved in NSW and SA corporations prior to ԭ involvement, the question must be asked, what benefits will accrue through greater regulation? On the other side, the compliance costs for our business are increasing exponentially. Below is a graph of MIs cost performance since privatisation in 1999, in comparison to CPI and bulk water costs. Real reductions of 35% have been achieved in this time. This is becoming increasingly difficult under the new regulatory regime.  It would appear from this discussion paper that the ԭ envisages a role in regulating not only the establishment of market rules, but also price setting, infrastructure planning, customer consultation, service standards, dividend policy and financing. MI directors and management have the ultimate responsibility to the customer / shareholders to govern the business to acceptable standards including the functions described above. We see no role for the ԭ in regulating how these functions are undertaken in private sector companies such as ours, where there are effective, self-regulating checks and balances. It is somewhat perplexing that in the interests of competition the ԭ is seeking such high levels of uniformity across a range of issues in the rural water sector we would have expected a focus on competitive diversity instead of uniform mediocrity. The only legitimate role for the ԭ is to regulate the pricing of service termination and related impacts on trade, presumably for the broader national interest. This can be done quite independently of the annual business processes described. Response to questions raised in the accc paper Question 1 Are there any matters not mentioned above that are relevant in establishing a methodology for determining prices consistent with the objectives and principles of the Act? We have addressed this matter in general terms above. Question 2 Are there any issues the ԭ should be aware of in relation to service standards? Provide details including: to what extent the proposed level of service is or should be communicated to customers during the price-setting process the role of customers when establishing service standards the role of customers in determining the balance between the level of prices and the standard of service the extent to which service standards are, or should be, reported publicly the extent to which service standards form, or should form, part of a customer service contract the types of service standards that currently exist. We do not consider this to be a matter for the ԭ. The nature and extent of consultation with customers is a matter for each operator. MI has a commitment to define, monitor and report service standards to our customer/shareholders and in so doing strive to improve such services over time. We see no obligation to report such standards to anyone else. Ultimately, if standards drop, our customers will firstly exercise their democratic right to change company direction and in the absence of success they can remove their investment from the district. Question 3 Are there any issues the ԭ should be aware of in relation to legislative and regulatory obligations? Provide details, including: to what extent obligations are, or should be, clearly articulated by regulators and government the types of obligations placed on operators how the obligations currently placed on operators are, or should be, funded the extent to which obligations are applied consistently across the basin? MI is concerned about the excessive burden that new regulations are imposing on our business and therefore our customers. The increase in costs through federal regulation is of particular concern. MI is confident that private diverters and other infrastructure operators, due to their different structure, are not facing the same regulatory and administrative burden. MI and other private operators now have over a decade of demonstrated success regarding efficiency reform, service improvement, water trading development and commitment to regional environmental protection. All of this has been achieved in the absence of significant regulation. It is unfortunate that MI and other private operators are now having to accommodate the lowest common denominator when it comes to regulatory intervention and policy reform. Question 4 In transitioning towards upper bound pricing: What factors may influence the path or pace of transition? How might these factors be addressed? Are there circumstances in which upper bound pricing cannot or should not be achieved? MI will provide detailed comments on this issue in an addendum to this submission. Question 5 To what extent are the two approaches applied consistent with the conditions listed above? Are there any issues that the ԭ should be aware of when considering the two approaches? Provide details, such as: the current approach, or what might be considered an appropriate approach, for determining forward-looking capital expenditure need whether forward-looking expenditure programs are independently audited and, if so, at what frequency what type of expenditure is suited to the renewals annuity approach the period over which the renewals annuity and regulatory asset base expenditures are discounted and included in prices how often the renewals annuity and associated bank surpluses or deficits are adjusted what discount rate (or rate of return) is used under both approaches what factors should be taken into account in determining the discount rate whether there are any inhibitors to using the weighted average cost of capital as the discount rate and whether it is appropriate to use this approach whether any operators recover a value of past investments in future prices The approach taken is a matter for each operator and will be determined by expenditure profiles, preferences to risk and consideration of intergenerational equity. MI uses the annuity approach to future CAPEX planning. The model was developed by an external consultant with the close involvement of MI technical and financial staff. The policy concept has the broad support of our customer/shareholders. MI provided details on this model to the ԭ in our last submission, including the assumptions used therein. The annuity will be reviewed and adjusted every five years in the absence of major changes to the underlying assumptions, in which case a specific review will be undertaken. Our current accelerated CAPEX program, using what remains of the NSW Government asset funding deed for deferred maintenance, is externally audited by the NSW Government. This process includes an ex-ante review of forward estimates of 2 years, a detailed ex-ante review of the annual works program and an ex-post audit of works completed. MI does not recover the value of past investments in future prices, unless specific cost sharing agreements were reached to provide levels of service above the standard. Such agreements are few in number. Question 6 Are there any issues that the ԭ should be aware of in relation to asset valuation? Provide details, such as: how operators currently finance capital investmentswhether it is solely through the renewals annuity or through a combination of the annuity and separate contracts with certain customers (maintaining a separate asset base for pricing purposes) under the regulatory asset base approach how existing assets should be valued in what circumstances might it be reasonable to revalue assets under the regulatory asset base approach? Are there any characteristics of irrigation assets that lend themselves to any particular asset valuation methodology? MI predominantly uses the annuity approach to capital finance. Decades of mismanagement by successive governments precipitated the changed approach under local ownership. MI is confident that the current approach provides the greatest security and equity for current and future generations. Our system is characterised by long life assets and lumpy expenditure profiles. The annuity approach suits this CAPEX profile. Where specific assets are required over and above standard levels of service, MI has and will continue to seek developer contributions towards such assets. MI will provide additional comments on this issue in an addendum to this submission. Question 7 Are there any issues that the ԭ should be aware of in relation to taxation? Provide details, including: whether operators are subject to either the Federal Income Tax or National Tax Equivalent Regimes? the implications for prices where varying tax obligations apply across the Basin the extent to which taxation liabilities are calculated in a manner similar to the table above and details of any differences any relevant issues, rulings, or tax laws that may influence the estimation of taxable income for the purpose of constructing a revenue requirement for pricing examples of where a significant, inexorable, real tax timing disadvantage has been experienced from the receipt of termination fees MI will provide detailed comments on this issue in an addendum to this submission. MI is subject to the federal income taxation regime. Question 8 To what extent do operators prepare, or should operators prepare, plans and undertake consultation processes for future capital and operating expenditure requirements? Where possible, provide details, including details of: the consultation process undertaken by operators when developing capital and operating plans, and the role of customers in this process independent review of asset management plans and operating and capital plans, and to what extent these reviews ensure that prices are based on prudent and efficient expenditure how often independent reviews are undertaken the role, if any, of independent consultants in the preparation of plans to what extent the results of independent reviews are, or should be, made public and reflected in prices programs currently in place, or that should be in place, to improve productivity and efficiency over time. We do not consider this to be a matter for the ԭ. The process for developing capital and operating plans is a matter for Directors of MI and these processes are broadly supported by our customer/shareholders. How other operators undertake such planning is a matter for them. Time is the best judge of success and we are confident that our long term performance in terms of efficiency and service improvements speaks for itself. Question 9: What principles and approaches are most appropriate when allocating fixed or common costs of irrigation delivery services (i.e. those costs that do not vary with the volume of water supplied)? Provide details, including: to what extent embedded cross-subsidies or community service obligations (CSOs) currently exist within irrigation networks; in what circumstances and to what extent such cross-subsidies or CSOs should be maintained in perpetuity; and what processes are, or could be, used to reduce or eliminate crosssubsidies and CSOs to what extent current charges do, and whether they should, reflect a uniform or postage stamp pricing policy to what extent current charges do, and whether they should, reflect the costs of providing services to different segments of the market MI has sought to remove, as far as practicably possible, cross subsidies in its pricing of services. In the absence of 3200 individual unit rates, a different rate for each customer, it is impossible to completely eliminate cross-subsidies. In MIs view, supported by our customers, the new system successfully groups those customers that demand similar services and therefore drive similar costs within the business. Within these groups, which combine elements of service levels, geography and system type, postage stamp pricing is the only practical means of sharing costs without a massive increase in the administrative burden for MI. Even with additional intellectual effort and improved data collection, many aspects of cost in a highly integrated network are simply not black and white as to key drivers. MI does not have any formal community service obligations although we have previously reported on a range of activities that the company undertakes which arguably go beyond the realm of good corporate citizenship. Question 10 To what extent and in what circumstances should the setting of fixed and volumetric charges be allowed to deviate from the underlying (fixed and variable) cost structure of the operator? This is a matter for each operator and they should be free to determine pricing policy that best suits their own needs. If other providers wish to include or exclude various pricing elements to the benefit or detriment of their customers it is of no concern to MI. However, to the extent that operators seek to use pricing policy to bias termination fees and trade then it is a matter for the ԭ and a matter of concern to MI. MI has identified a mechanism which effectively allows operators to determine an annual pricing system independent of termination fee regulations. This is described later in our response and deserves more serious consideration by the ԭ. Question 11 To what extent is pricing used as a cash management tool or insurance fund for irrigators? Are operators best placed to provide this service? What are the practical implications for the trade of water under such a pricing arrangement? Since before privatisation MI has been using a price stablisation matrix whereby funds from good years are set aside in cash deposits for use in difficult years. This system has been fundamental to the survival of the Company and our customer/shareholders during the recent extended drought. Only after 5 years of drought did the company exhaust the funds that had been set aside in prior years and customers have been appreciative of the stability that this has helped facilitate in otherwise difficult circumstances. MI is committed to retaining a reserve system and has factored in a revised scheme to its new pricing system, again with the broad support of customers. No-one is better placed than MI to manage such a fund for our customers. Our Directors are able to effectively balance the risks and rewards to the Company and customers, including decisions on investment policy. Directors have a responsibility under the Corporations Act to develop sound risk management strategies and given the reliance of the business on one major income source we would argue that such a fund demonstrates sound practice. MI does not believe that the operation of the reserve fund has any substantive impact on water trade. Even if it did this would be insufficient reason to abandon a policy that is both effective and broadly supported. From a public perspective the operation of the reserve helps to alleviate the pressure on public assistance during difficult times such as the current drought. MI does not believe that this is a matter for the ԭ. Question 12: What progress has been made in the implementation of the access, exit and termination fee protocol to schedule E of the Murray darling Basin Agreement specifically in relation to the creation of delivery entitlements? MI is concerned that re-opening or reviewing previous decisions about termination fees in too short a time frame creates unnecessary uncertainty and costs for irrigation farmers and their infrastructure service providers. The Company therefore recommends that the primary focus on termination fees should be to ensure compliance and investigate low cost ways of achieving compliance for irrigation infrastructure operators. Murrumbidgee Irrigation is compliant with the termination fee protocol to schedule E. It has created Delivery Entitlements (DEs) in practice but further changes to water supply contracts and the constitution are needed. These changes are are scheduled for shareholder consideration in November 2008. The current situation is therefore as follows :- For internal permanent trades, DEs must be traded with the Water Entitlements (WEs) pending legal definition of DEs in the contracts / constitution. For external permanent trades, customers have the choice of retaining the notional residual DEs and continuing to pay annual fixed charges, or cancellation of their delivery service and payment of the Termination Fees. Question 13 To what extent and in what circumstances does the creation of explicit delivery entitlements impact the operation of irrigation networks? The introduction of delivery entitlements has created a significant increase in complexity and transaction costs for operations. It has the potential to impact on the investment and trading decisions of customers and potential customers. MI is very concerned that we mitigate such negative impacts. MI does not expect significant benefits through trade in delivery entitlements. The driving factor in making these changes is compliance. The disadvantages lie in the complexity, transaction costs and unlikely benefits of DEs in a highly integrated common service system. However, the main costs potentially lie in impacts on trade and investment decisions. For example, there is much more uncertainty involved with buying farms and water (given the additional need to specify the status of delivery entitlements). MI must now introduce an additional register and set of contracts to deal with delivery entitlements (and prospective trade in those entitlements temporary or permanent). Definition of the entitlement is quite simple at a theoretical level based on service standards (flow rate shares), however in practice the theory can be unworkable at times from a property rights perspective. Great care needs to be taken to ensure that previous and potential investments by customers and shareholders are not compromised at a practical level in the transition period. Question 14 To what extent have the specific provisions of schedule E for dealing with explicit delivery entitlements been met by operators? Until constitutional changes have been approved by shareholders, internal trades of WEs carry with them the requirements in relation to DEs. MI has no alternative at present. Question 15 To what extent and in what circumstances are the security provisions within schedule E applied by operators? MI is compliant with the security provisions in schedule E. MI has previously explained its concerns about revenue security on a dewatered property. The following is extracted from our submission to ԭ on the Market Rules issues paper (dated 8 May 2008). A typical balance sheet for a watered property would see water entitlement ranging from about 80% to 95% of total assets, with a capitalized liability for delivery entitlement in MI of about 15% of water entitlement. The risk to the revenue of operators when land that is serviced by irrigation infrastructure does not have water access entitlement is captured by the worst case where the farm is rendered a dry area property. There is no particular reason to expect that the property would do any better than current dry area properties, and most evidence suggests it would do worse. This means that the farm would have significantly lower than average returns because of the additional annual costs of meeting fixed delivery access fees and reduced income. That presents special challenges for operation of such a farm. If it runs into financial difficulty the question becomes, what percentage of the liability to MI could be claimed from remaining net assets (after the water has gone)? In many cases the remaining net assets would not cover the capitalized liability of water delivery fees. MI has accepted the current Schedule E Protocol in respect of seeking security over future payment of access fees. At the time we stated a preference for enabling security when the value of retained water falls below the value of the termination fee on delivery entitlements (rather than 50%). That preference remains. In the absence of any security arrangements the default risks would undoubtedly increase costs for remaining producers which would in turn lead to more exits and a self reinforcing downward spiral. The security arrangements may lock up some capital but are consistent with reasonable risk sharing between operators and individual members. If some members can shift all risks to the operator then it is likely that a large free-rider problem will emerge and make investment in water delivery services very difficult. This is likely to result in sub-optimal investment in irrigation services. There are alternatives such as bank guarantees, but these would tie up capital in the same way as using irrigation rights as security. The security should be consistent with the value of the remaining liability for delivery entitlement to the operator. If capping is necessary to achieve that then it should be considered. Note that there are two issues which may require different treatment. The first relates to security over payment of annual fixed and variable charges. The second relates to security over payment of the termination fee. The latter is likely to prove the most difficult to manage. Question 16 To what extent have the provisions of Schedule E in relation to prohibiting the levying of exit been adhered to by operators? MI does not levy exit fees on water entitlement. It is concerned about the impacts of any non-compliance on those that are complying with schedule E, and will continue to monitor the situation. The collective governments need to make their intentions public regarding dealing with non-compliance. Question 17 In relation to the levying of fees and charges, do access fees recover an operators fixed costs and do operators calculate a separate levy for infrastructure service improvements? MI is now in year two of a three year transition towards the new pricing regime. At the completion of the transition, MIs access fees will recover the fixed costs. Separate charges are levied for services and infrastructure provided above the standard levels of service. Question 18 What factors impact on the choice to levy a separate fee or charge outside the renewals annuity? The Company investigates and negotiates separate fees and charges if customers or shareholders request levels of service beyond the standard Company levels of service provided to each pricing group. Question 19 Have all operators adopted a multiple of 15 times the annual access fee? Cancellation of service has now been split into 2 components within MI - termination and disconnection. Termination is based on 15x multiples of the annual fixed facilities charges (15 x each ML of DE cancelled). Disconnection is based on a flat $2,500 fee per property notwithstanding that the annual fixed charges per property average over $1000 per annum. The disconnection includes the last ML of DE cancelled. Across both charges therefore, the average collection is now less than 15 x the annual fixed charges. We do not monitor other infrastructure operators on this basis, but we would be concerned if the multiple of 15 is being exceeded. Question 20 Have any operators made an allowance in termination fees for avoidable costs associated with the surrendering or termination of a delivery entitlement? It is important that termination fees be charged using consistent methods and at consistent rates for all customers. Otherwise MI might be subject to criticisms of bias in its dealings with customers. Within this context MI has developed a standard process for assessing the avoidable costs in termination and disconnection and where relevant this process is employed. MI is currently investigating options for broader landscape change that might involve more structured programs of decommissioning, as part of the MI Future Landscapes Project. Question 21 Which multiple/number if years (if any) represents a reasonable balance between removing potential barriers to trade and providing a sufficient timeframe for operators to adjust to new trade patterns, receive the appropriate investment signals and efficiently rationalise irrigation networks? MI has previously advocated its preference for a reducing average, flat rate fee across comparable systems, with structural adjustment funds being available to regions where fixed costs and termination requirements are on the wrong side of the average. The current 15 times approach has resulted in perverse and unintended pricing outcomes, whereby the most inefficient regions have the highest termination fees and therefore the greatest protection from asset stripping. Notwithstanding the above, if the current approach is to be retained then MI supports the multiple of 15 times because: It has already been agreed and the application of a more theoretically correct number is likely to impose more costs than benefits. The theoretically correct multiple should reflect a reasonable choice between whether to pay the termination fee or continue meeting annual access fees. The payer is likely to choose the least cost approach. This will likely vary according to circumstance. Murrumbidgee Irrigation has not been able to discern any trend towards choice of termination fee or access charges. The main trend is seemingly to try and avoid both the fee and the charges. If there were customer contracts with explicit provisions for termination it is likely that the termination clause would be close to the multiple of 15. The more important issue is the level of fixed access charges and the variation in those charges across similar irrigation infrastructure services. Question 22 Aside from transitional issues, are there any circumstances under which a shadow access fee should be retained? No. The current arrangements for shadow access fees are acceptable. Question 23 Are there instances where termination fees or charges applying to delivery entitlements are calculated on a basis other than an actual or shadow access fee as specified in Schedule E? What practical or other reasons account for such practices? MI does not calculate termination fees on any basis other than schedule E (as a maximum charge). Question 24 Would operators be at a competitive disadvantage by having lower actual delivery access and termination fees? MI is convinced that relative efficiency is important because the most cost efficient infrastructure service providers (ie, those with the lowest access fees) are cheaper to buy out than inefficient providers (with high access fees). The critical indicator that will determine whether efficient service providers are disadvantaged will be whether termination fees are simply an addition to water entitlement prices (ie, paid for by the buyer) or whether they are net of water entitlement prices (paid for by the seller). The efficient operators will be disadvantaged in the former but not the latter case. It is probably too early to be definitive but termination fees seem to be adding significantly to water entitlement prices in markets with which MI is familiar. Question 25 Are taxation adjustments made to termination fees? On what basis are they made? MI currently makes no adjustment for tax in the calculation of its termination fees. MI will review this position in light of how other operators are interpreting their costs. ԭ must clarify its position in relation to taxation treatment, including the legitimacy of taxation as a business operating cost and the legitimacy of accounting for the taxation affect of lump sum payments. Further clarification on any aspect of this submission can be obtained by contacting the Griffith office on 0269620200 or Leeton office on 0269530100. 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