MUNICIPAL TARIFF GUIDELINE, BENCHMARKS AND PROPOSED TIMELINES FOR MUNICIPAL TARIFF APPROVAL PROCESS FOR THE 2013/14 FINANCIAL YEAR Cnsultatin Paper 19 Nvember 2012
Abbreviatins and Acrnyms APP Average Purchase Price ASP Average Selling Price B Bulk Purchase BPI Bulk Purchase Increase C Capital Charges CCI Capital Charges Increase CPI Cnsumer Price Index D-frms Distributin Frms DSM Demand Side Management EPT Electricity Pricing & Tariffs ERA Electricity Regulatin Act IBT Inclining Blck Tariff IRM Infrmatin Resurce Management kva Kilvlts-Amps kwh Kilwatt-hur LF Lad Factr MD Maximum Demand MFMA Municipal Finance Management Act MWh Megawatt-hur MYPD Multi-Year Price Determinatin NERSA Natinal Energy Regulatr f Suth Africa OC Other Csts OCI Other Csts Increase R Repairs RI Repairs Increase S Salaries SI Salaries Increase TOU Time-f-Use WACC Weighted Average Cst f Capital 1
1. Executive Summary The Natinal Energy Regulatr f Suth Africa (NERSA r the Energy Regulatr ) is the regulatry authrity ver the energy sectr in Suth Africa and its mandate includes the regulatin f the electricity supply industry. In terms f sectin 4(ii) f the Electricity Regulatin Act, 2006 (Act N. 4 f 2006) ( the ERA ), the Energy Regulatr must regulate electricity prices and tariffs. The Energy Regulatr apprves an annual percentage guideline increase which is issued t municipalities prir t them preparing their tariff adjustment applicatins. This assists municipalities in preparing their budgets s that they can submit tariff applicatins t NERSA n time. This guideline des nt preclude a distributr frm the legal bligatin t apply t the Energy Regulatr fr tariff increases befre implementatin. NERSA als reviews the tariff benchmarks and recmmends new benchmarks t be used in the evaluatin f the municipal tariff evaluatins. Cmments n the cnsultatin paper shuld be sent t: Ms Tabisa Nkp at the Natinal Energy Regulatr f Suth Africa, Kulawula Huse, 526 Madiba Street (frmerly Vermeulen Street), Arcadia, Pretria. E-mail: municguideline@nersa.rg.za. The deadline fr the submissin f cmments is 10 December 2012. After the cnslidatin f all the cmments frm stakehlders, NERSA will hld a public hearing in February 2013. NERSA wishes t state that the success f this prcess will depend n rbust stakehlder participatin. 2. Backgrund This cnsultatin paper is limited nly t price r tariff adjustments by municipal distributrs and the municipal tariff applicatin and apprval prcesses. Eskm s prices are determined under a separate apprach and methdlgy. The apprach fllwed by NERSA allws licensees t submit their prpsed price adjustments r tariff increases annually fr apprval by the Energy Regulatr. This is dne based n the percentage guideline increases issued by the Energy Regulatr t all municipal distributrs, based n the apprved Eskm price. The submitted prpsals are evaluated by staff and recmmendatins are made t the Energy Regulatr fr apprval. In determining the indicative guideline increase NERSA takes int cnsideratin the apprved Eskm bulk price f electricity t municipalities, and the increase n the municipalities cst structures. It shuld be nted that due t the fact that the Energy Regulatr will make a determinatin n the Eskm price increase in February 2013, NERSA has develped an indicative guideline based n varius scenaris. The apprved indicative guideline will in the interim assist municipalities in their budgetary prcesses. 2
2.1 Issues cnsidered in the analysis f the municipal tariff review The csts deemed nt t be in the direct supply f electricity will be dealt with n a case-by-case basis frm each municipality. These will be determined by cmparing the municipalities average cst t supply electricity with the average price charged by the municipalities. The difference will then be used t adjust the verall increase awarded t the municipality. In determining the average cst t supply the fllwing factrs, amngst thers, will be taken int accunt: 1. bulk purchases; 2. bad debts; 3. reasnable energy lsses; 4. salaries and wages; and 5. capital charges. Furthermre, the municipalities verall financial and technical perfrmance will be reviewed prir t a final decisin n the verall increase. Indicatrs t be cnsidered in this regard mainly include: 1. percentage surplus; 2. percentage energy lsses; 3. percentage pwer csts; 4. bad debt prvisin; and 5. average purchase price/average selling price rati. 2.2 Submissin f D-frms infrmatin In rder t ensure that a prper analysis is dne and apprval f tariff applicatins is achieved, NERSA requires crrect and cmplete infrmatin by which the tariffs are t be determined. T this end, a need fr cnsistent and high quality infrmatin has been identified. The required infrmatin fr tariff analysis and apprval includes bth qualitative and quantitative data and must be in a frm that is cnsistent with NERSA s bjectives insfar as tariff principles are cncerned and as stipulated in the ERA. Fr municipal tariff applicatins t be prperly analysed, NERSA depends entirely n the accurately cmpleted infrmatin prvided in the Distributin frms (D-frms). D-frms that are primarily used fr tariff apprval prcesses are D1 (Financial infrmatin), D2 (Market infrmatin) and D3 (Human Resurces infrmatin). These frms cntain infrmatin regarding the financial health and efficiency levels f the municipality, and als prvide data regarding cnsumptin and number f custmers per tariff categry, which will assist NERSA in its tariff 3
analysis. The infrmatin als assists in determining the financial health f the municipality and in determining the revenues that the municipality cllects frm the varius tariff categries (fr example, the D-frms demnstrate the custmer mix f the municipality and where the municipality cllects the bulk f its revenue). In the absence f the D-frms, r where inaccurate infrmatin is supplied, the analysis might nt fully reflect the true financial r technical state f a licensee, wh culd be in a desperate financial situatin that culd therwise have been minimised, had accurate infrmatin been prvided. Licensees are therefre urged t ensure that crrect and accurate infrmatin is timeusly submitted t NERSA. Access t the D-frms templates can be btained thrugh the NERSA website (www.nersa.rg.za). It must be nted that the clsing date fr the submissin f the D-frms was 30 Octber 2012, and that any municipal tariff applicatin withut the submissin f apprpriate D-frms infrmatin will nt be cnsidered. Stakehlder Cmment #1 Stakehlders are requested t cmment n what measures NERSA shuld put in place in rder t btain quality data frm municipalities that wuld assist NERSA with its tariff analysis? 3. Determinatin f the municipal tariff guideline It shuld be nted that the indicative guideline that has been develped in this cnsultatin paper is nt the final apprval f the Energy Regulatr, since the determinatin n Eskm s MYPD3 applicatin will be dne n 28 February 2013. NERSA has develped the indicative guideline, based n varius scenaris t assist municipalities with their budgetary prcess. When develping the percentage guideline increase fr 2013/14, the fllwing issues were cnsidered and sme assumptins made. The guideline fr the 2013/14 financial year has been calculated after taking int cnsideratin Eskm s MYPD3 applicatin. In the MYPD 3 applicatin Eskm has prpsed a 16% average increase fr the 2013/14 financial year. This increase amunts t 14.40% 1 fr the municipalities. Hwever, since this increase has nt been apprved as yet, NERSA has calculated municipal tariff guideline based n varius scenaris as shwn in Table 2 belw. The municipalities were divided int different cnsumptin sizes based n their bulk purchases frm Eskm. The determined different sizes are small, medium 1 The 14.40% is indicated as the bulk purchase increase applicable t municipalities. 4
and large, respectively (0 50 MWh), ( 51 750 MWh) and ( > 750MWh). This analysis was dne in rder t determine whether the weights f the cst drivers are still relevant fr the develpment f the guideline fr the 2013/14 financial year. The analysis dne indicated that the weights f the cst drivers can still be utilised, in determining the weighting f the electricity supply csts fr the 2013/14 financial year. Table 1: Municipal cst structures % Purchases 70 % Salaries and Wages 10 % Repairs 6 % Capital charges 4 % Other csts 10 The fllwing assumptins n cst increases were made:- bulk purchases will increase by a range f between (5.3% t 14.40%) 2 in line with Eskm s increase t municipalities; Cnsumer Price Index (CPI) 5.3% 3 ; salary increases CPI plus 1.25% 4 ;and repairs and maintenance, capital charges and ther csts will increase by CPI. The prpsed Eskm price increase fr Municipalities: Municipal distributrs purchase their energy requirements frm Eskm, wh generates 96% f the energy that is cnsumed in the cuntry. It is therefre necessary that when cnsidering the level at which municipalities will increase their tariffs, the Eskm price increase be taken int cnsideratin. The analysis f ther municipal csts besides purchase csts: While purchase csts make up the bulk f municipal csts (an average f 70% based n the sample used in the analysis) municipalities are als subjected t ther csts like perating and maintenance csts. Increases in these csts have a bearing n the municipalities ability t distribute electricity. 2 The range fr the bulk purchase increase is based n the varius scenaris that NERSA is assuming. 3 As indicated in the Medium Term Budget Plicy Statement 2012(MTBPS) 4 As indicated in Circular N. 6/2012: Salary and Wage Cllective Agreement 5
The frmula fr calculating the guideline MG = (B x BPI) +(S x SI)+(R x RI)+(C x CCI)+(OC x OCI) Where:- MG = % Municipal Guideline Increase B = Bulk purchases as percentage f ttal cst BPI =% Bulk purchase increase S = Salaries as percentage f ttal csts SI = % Salaries increase R = Repairs as percentage f ttal csts RI = % Repairs increase C = Capital charges as percentage f ttal cst CCI = % Capital charges increase OC = Other csts as percentage f ttal cst OCI= % Other csts increase Table 2: Calculatin f the guideline fr the 2013/14 financial year based n varius scenaris SCENARIO 1: (5.3% increase) SCENARIO 2: (10.0% increase) SCENARIO 3: (14.40% increase) REVISED COST LINE ITEM MUNIC % OF TOTAL COST EXPECTED INCREASE % WEIGHTED AVERAGE EXPECTED EXPECTED INCREASE INCREASE % WEIGHTED AVERAGE EXPECTED EXPECTED INCREASE INCREASE % WEIGHTED AVERAGE EXPECTED INCREASE Purchases 70% 5.30% 3.71% 10.0% 7.00% 14.40% 10.08% Salaries and wages 10% 6.55% 0.66% 6.55% 0.66% 6.55% 0.66% Maintenance/Refurbishment/recapitalisatin 6% 5.30% 0.32% 5.30% 0.32% 5.30% 0.32% Capital charges in ttal 4% 5.30% 0.21% 5.30% 0.21% 5.30% 0.21% Other charges 10% 5.30% 0.53% 5.30% 0.53% 5.30% 0.53% % increase 5.43% 8.72% 11.80% 6
3.1 Municipalities applying fr an increase that is abve the guideline will have t justify their increases t the Energy Regulatr and the decisin will be based n the fllwing requirements: 1. a full analysis f additinal funds requested needs t be presented t NERSA as part f the mtivatin fr the abve-guideline increase (the municipality must give a detailed revenue analysis where it indicates the revenue when using the apprved guideline percentage increase and add the revenue and list f items, i.e. repairs and maintenance, where the extra funds will be allcated); 2. the apprved funds must be ring-fenced t ensure that it is strictly utilised fr the identified prjects; 3. municipalities must reprt t NERSA n a six-mnthly basis n hw the additinal funds are utilised; and 4. funds nt utilised fr the purpse fr which they were apprved will be clawed back in the fllwing financial year. Stakehlder Cmment # 2 Stakehlders are invited t cmment n whether municipalities shuld be granted an increase that is abve the guideline, if nt, t prpse pssible alternatives fr municipalities t cllect their required revenues. 4. Municipal Electricity Tariff Benchmarks The existing benchmarks are based n five assumed tariff/custmer categries and average cnsumptin levels fr these categries. It shuld be nted that these are average cnsumptin levels and that there may als be ther tariff classes at varius municipalities which will cater fr ther custmer classes r cnsumptin levels that are very different frm the nes that are assumed. Where such different circumstances exist, the applicatins will be treated n a case-bycase basis. Municipalities applying fr tariffs that are utside the apprved benchmarks must justify such increases and the fllwing infrmatin must be submitted: 1. the ttal number f custmers per tariff categry municipalities that d nt have an apprpriate custmer base must submit the full detail f its custmer prfile, as well as the assciated revenues; 2. expected revenues per tariff categry; 3. the frecasted ttal sales; 4. the average maximum demand per tariff (where applicable); 5. the average lad factr (where applicable); and 7
6. the lad prfile in percentages (bth summer and winter, where applicable). 4.1 The municipal custmer categries In develping the benchmarks, NERSA has been assuming the fllwing custmer classes: Dmestic Tariffs - Blck 1 (1 50 kwh); - Blck 2 (51 350kWh); - Blck 3 ( 351 600kWh); and - Blck 4 (> 600kWh). Cmmercial (small business) single phase tariff An average cnsumptin level f 2000kWh per mnth. Cmmercial Prepaid An average cnsumptin level f 2000kWh per mnth. Industrial/Large user tariff A 30.00% lad factr (LF) and a maximum demand (MD) f 200kVA, which wuld give an average cnsumptin level f 43 800kWh. Industrial Time-f-Use (TOU) A 30.00% LF and an MD f 200kVA, which wuld give an average cnsumptin level f 43 800kWh. The custmer prfile (i.e. peak, standard, ff peak). 4.2 The NERSA review prcesses Due t sme cncerns that have stemmed frm the industry, NERSA has embarked n rigrus prcesses in rder t address the cncerns f the stakehlders. As a result f these cncerns NERSA is reviewing the current municipal tariff benchmarks. 1. NERSA is currently in the prcess f reviewing municipal tariffs, bth within each municipality and acrss all municipalities. The decisin f the Energy Regulatr in reviewing such tariffs will have t be incrprated when develping the benchmarks as this will have an impact n the apprved tariff structures. 2. The Energy Regulatr is expected t make a decisin n the review f the Inclining Blck Tariffs (IBTs) in December 2012. This will assist in determining apprpriate tariff structures that will suit municipalities specific circumstances. 8
3. NERSA has received a large vlume f cmplaints n the unit csts f the demand that municipalities charge. These cmplaints indicate the excessive kva variatins between municipalities and Eskm. 3.1 The cst f sevice (COS) study wuld be a key resurce fr an apprpriate rate design fr municipalities. It is fr this reasn that municipalities are encuraged t undertake COS studies. In the absence f such studies NERSA will benchmark their tariffs with the Eskm tariffs. 3.2 The municipalities with high demand charges and lw energy charges are encuraged t restructure their tariffs by shifting a prtin f the demand cst recvery frm the demand charge t the energy charge. 3.3 The Eskm review tariff analysis based n the MYPD 3 applicatin is als under way, and the decisin n the apprved structural tariffs will be in February 2013. This will als have an impact n the tariff structural changes f the municipalities. 3.4 Municipalities must als cnsider the lad factrs f their custmers when determining the kva charge and give ptins t custmers with a high r lw lad factr. Stakehlder Cmment # 3 Stakehlders are requested t cmment n the NERSA prcesses that are underway. Stakehlder Cmment # 4 Stakehlders are invited t cmment n the phasing in f the alignment f the municipal demand and energy charges t thse f Eskm. 9
5. Financial Benchmarks Table 3: Financial benchmarks Current Average Benchmarks Revised Benchmarks Average Financial Benchmarks (Tlerable Range) Percentage Pwer cst 70% 70% 58% - 78% Percentage Surplus 15% 15% 10% - 20% System lsses 10% 10% 5% - 12% Average Purchase Price/ Average Sales Price rati 1: 2.1 1: 1.64 NERSA is in the prcess f gradually reducing the average purchase price and average sales prices rati. As the high price variatins between the municipal and Eskm tariffs have becme nticeable. In revising the Average Purchase Price /Average Selling Price (APP/ ASP) rati a sample f 115 municipalities was used t determine an average APP/ ASP rati. The infrmatin frm the 2010/11 distributin frms was used t determine this average. Stakehlder Cmment # 5 Stakehlders are invited t cmment n whether the financial analysis is apprpriate fr determining the efficiency f the municipality. 6. Timelines fr municipal tariff apprval prcess and guideline determinatin Municipalities are bund by amng ther legislatins, the Municipal Finance Management Act (MFMA) and Municipal Systems Act. Accrding t the MFMA budgetary prcess, Natinal Treasury issues a budget circular annually t all municipalities by the end f Nvember.Ideally, this circular shuld take int accunt NERSA s apprved guideline increase; hwever this will nt be pssible in the current cycle due t the guideline determinatin being dependent n the apprval f the MYPD3, which will nly ccur n 28 February 2013. NERSA will prvide Natinal Treasury with the indicative guideline which municipalities can use t base their draft budgets n. It is anticipated that municipalities will cmpile and submit draft tariff applicatins fr NERSA s cnsideratin frm January 2013. NERSA will then determine and apprve the final municipal tariff guideline n 28 February 2013 5. The apprved guideline will be cmmunicated t municipalities wh will then adjust their budgets accrdingly. Sectin 43 f the MFMA (Act N. 56 f 2003) states that: 5 Tentative date (NERSA 2013 shedule f meetings nt yet apprved) 10
(1) If a natinal r prvincial rgan f state in terms f a pwer cntained in any natinal r prvincial legislatin determines the upper limits f a municipal tax r tariff, such determinatin takes effect fr municipalities n a date specified in the determinatin. (2) Unless the Minister n gd grunds apprves therwise, the date specified in a determinatin referred t in subsectin (1) maya) If the determinatin was prmulgated n r befre 15 March in a year, nt be a date befre 1 July in that year; r b) If the determinatin was prmulgated after the 15 March in a year, nt be a date befre 1 July in the next year. Based n the delay in the determinatin f the municipal guideline and n the abve-mentined MFMA cnstraint, NERSA has requested an extensin f the timelines fr the finalisatin f the municipal electricity tariff determinatin frm the Minister f Finance. The table belw shws the timelines and prcesses leading t the apprval f municipal electricity tariffs. Table 4: Timelines and prcesses leading t the apprval f municipal electricity tariffs NERSA/ MUNICIPAL PROCESS Due date fr municipalities t submit their D-frms fr the next tariff applicatins prcess Mdelling f municipal tariff guideline & benchmarks Publishing f the cnsultatin paper n NERSA website Public Hearing fr the municipal guideline increase and benchmarks NERSA s decisin f the municipal guideline increase and benchmarks Cmmunicate guideline increase t municipalities ACTIVITY/TASK NATIONAL TREASURY/MFMA BUDGETARY PROCESS Natinal Treasury issues a budget circular t all municipalities Mayr tables municipal and entity budgets and budget related plicies (Draft) fr cnsultatin prcesses DATE 30 Oct 12 Oct Nv 12 16 Nv 12 End Nv 12 05 Feb 2012 28 Feb 13 01 Mar 13 Mar 13 Municipalities cmpiles and Jan - May 13 11
submit tariffs applicatin fr cnsideratin by NERSA NERSA s cnsideratin and apprval f tariff applicatins and cmmunicatin f NERSA s decisin t municipalities Implementatin f apprved budget including NERSAapprved tariffs Public submissins n draft budget Cuncil hearings t cnsider submissins Mayr resubmit amended budget fr cuncil apprval and adptin Finalised budget is tabled in Cuncil again Apr- May 13 Feb - End May 01 June 13 01 Jul 13 Stakehlder Cmment # 6 Stakehlders are invited t cmment n the apprpriateness f the municipal tariff apprval prcess and timelines with regard t the MFMA prescribed budgetary prcess. End 12