PR19 Business Plan Water Resources RCV Allocation Submission January 2018
Introduction... 3 Overview of Company Water Resources... 3 Ofwat s Technical Guidance on Issues to Consider... 4 1. Definition of Water Resources... 4 2. Impact on Wholesale Tariffs... 5 3. Links to the Draft Water Resources Management Plan (dwrmp)... 5 4. Links to Bulk Supplies... 6 5. Roll Forward of Historic Net MEAV... 6 6. Revaluation of Net MEAV... 7 7. Potential for Reallocation at PR24... 8 Approach to Assurance and Board Assurance Statement... 8 Annex 1... 10 Board Assurance Statement on the Allocation of the Forecast RCV at 31 March 2020 to the Water Resources and Network Plus Wholesale Price Controls... 10 Annex 2... 12 Summary Calculations for MEAV Roll Forward... 12 Page 2 of 12
Introduction This submission contains the information required by Ofwat s PR19 Methodology to enable a separate binding price control to be determined from 1 April 2020. It has been compiled taking into account the specific guidance issued by Ofwat in: 1. The water resources pre-2020 legacy RCV allocation at PR19 - technical guidance (the Technical Guidance ) dated 31 January 2017; 2. Appendix 9 to the consultation on PR19 Methodology: Water resources legacy RCV allocation initial submission (the Initial Submission Guidance ) dated 11 July 2017; and 3. Appendix 5 to the final methodology for the 2019 price review: Water resources control (the Final Methodology Guidance ) dated 13 December 2017. It also employs the boundaries between the water resources and network plus business units and proposed price controls, and the allocation guidelines, set out in the latest Regulatory Accounting Guidelines (version 4.07). The Company has benefitted from participation in the Regulatory Accounts Working Group on 28 February 2017, water resources form of control workshops and particularly from the company meeting with Iain McGuffog the senior Ofwat officer leading the RCV allocation work stream on 19 May 2017. The submission should be read alongside Tables WS12 (RCV allocation in the wholesale water service) and WS12b (Wholesale water charges impact assessment) and comprises: a. An overview of the Company s position on water resources, including the composition of historic assets and the future water resources needs identified in the Draft Water Resources Management Plan submitted to the Secretary of State for the Environment on 1 December 2017. b. A consideration of the Issues for companies to consider in Ofwat s Technical Guidance. c. Commentaries on Tables WS12 and WS12b, including the general approach to the rollforward of the Modern Equivalent Asset Values (MEAV) to 31 March 2020 and the impact assessment on wholesale. d. A summary of the Company s approach to assurance and, as an appendix, the signed Board assurance statement. This submission is being published on the Company s website in its entirety under the Our Business Plan 2020 to 2025 section. Overview of Company Water Resources SES Water is primarily dependent upon groundwater sources, which meet on average 85% of normal supply needs from boreholes drawing on aquifers in the greensand and chalk deposits which cross the Company s supply area from east to west. On average 15% of supplies are drawn from the River Eden through a single abstraction point at Chiddingstone, which pumps water into the Company s only raw water reservoir at Bough Beech. The asset base, on both a historic cost and a MEAV basis, reflects this relatively straightforward water resources picture. The current cost analysis of fixed assets at 31 March 2015 included in the Company s audited regulatory accounts for 2014-15 shows: Page 3 of 12
000 s Gross Replacement Cost Accumulated Depreciation Net Book Value Infrastructure assets 18,852 0 18,852 Non-infrastructure assets 77,649 (24,895) 52,754 Total water resources assets 96,501 (24,895) 71,606 The infrastructure assets listed above is the single raw water reservoir at Bough Beech. Non-infrastructure assets comprise the series of boreholes used for abstraction from the greensand and chalk aquifers and the associated abstraction pumps. The breakdown of Net Book Values between the surface water and groundwater sources (as contained in the Company s MEAV asset register underpinning the audited and published regulatory accounts values) is shown below: 000 s Net Book Value Bough Beech Reservoir and associated surface water abstraction assets 24,390 Boreholes and groundwater abstraction assets 45,647 Management, general and scientific services assets 1,569 Totals 71,606 The Company has an historic bulk supply facility from Thames Water at Merton (last used in 2004) and is enabling the provision of facilities during the current AMP for South East Water to take a treated water bulk supply from Outwood Service Reservoir (supplied predominantly from Bough Beech WTW) under terms currently being negotiated. The Company s latest Draft Water Resources Management Plan does not change this overall picture materially. There are no supply side schemes included in the Plan until 2058 and an additional bulk supply to South East Water, included in the Water Resources in the South East modelling after the Company s own draft Plan had been concluded, has yet to be reflected in the Company s own draft Plan. This transfer, from Bough Beech WTW to SEW s Riverhill Service Reservoir, is planned to be in use from 2035. The principal focus of the Company s Draft Water Resources Management Plan on demand side management initiatives including a wider progressive metering programme for households, further water efficiency education measures and an ambitious leakage reduction programme (consistent with Ofwat challenges) will not be altered by this minor update. The water resource supply options and the mix of assets deployed in meeting demand are not therefore expected to change materially during the current planning horizons. Ofwat s Technical Guidance on Issues to Consider The Company has followed the unfocused approach to allocation of RCV between the water resources and network plus business units and proposed price controls, in line with the approach required by the Water 2020 Decision Document. The Company has allocated the forecast RCV at 31 March 2020 between business units based on the proportion of net MEAV employed in the business units relative to the total assets employed in the wholesale business. The consideration given to the issues identified in Ofwat s Technical Guidance is outlined below. 1. Definition of Water Resources Whilst the allocation of asset values between the Water Resource and other business units in the 2014-15 regulatory accounts was based on guidance that has been subsequently superseded by RAG 4.06, the potential impact of changes in boundaries and definitions was addressed for operating expenditure and historic cost asset values Page 4 of 12
for the 2016-17 annual performance report and regulatory accounts. Recognising the potential significance of changes in regulatory accounting guidelines, the Company commissioned a detailed cost allocation review from an experienced third party regulatory accountant, who worked with finance, engineering and operational staff across the business to understand the impact of changes in reporting requirements. The conclusions were fully reflected in the operating and capital expenditure allocations for the year between the Wholesale business units reported on in the Wholesale Totex Analysis for the year (Table 4D of the annual performance report) and in the analysis of historic cost fixed assets between all business units (Table 2D). Table 2D was subsequently independently audited by KPMG under the requirements for audits of regulatory accounts. No matters of non-compliance with the latest regulatory accounting guidelines were identified. The Company s MEAV register mirrors the historic cost register in comprising the same asset listing, with the same allocations to locations and business units as the audited historic cost register. Changes in allocations in one register can therefore be easily applied in the other, ensuring that all accounting asset records remain aligned and consistent. In fact, no material changes in allocations affecting the water resources business unit were identified for the 2016-17 annual performance report and no changes were made to the allocations at the 31 March 2015 starting point for the asset roll-forward. There are therefore no reclassifications to the historical information to be used for the forthcoming water resources price control. 2. Impact on Wholesale Tariffs Table WS12b includes the information underpinning the Company s assessment of the impact of the allocation of pre-2020 legacy RCV to water resources on the balance of wholesale charges for different customer segments. The Company s existing wholesale tariff structure includes discounted tariffs for large and medium users and a substantial special agreement for the supply of water to Gatwick Airport. In aggregate these charges accounted for 2.404k in 2016-17, or just over 4.5% of total wholesale revenue. All three categories of tariff reflect the savings in network operation and maintenance costs arising from the supply configurations typically involved in the supply of higher volumes of water to individual end users. The cost justification for these tariffs was considered extensively by Ofwat at the time of their introduction (and on occasion subsequently) and the Company s explanations and proposals were accepted. There have been no material subsequent changes in the supply arrangements that would require a review of tariff structures. The Company only has two bulk supplies, which generated 37k of income in 2016-17, less than 0.07% of total wholesale revenue. The tariffs reflect the agreements in place and align with the average revenue generated from all water sold. Table WS12b shows therefore than none of the Company s existing variations in wholesale charges are attributable to variations in water resources costs. The proposed allocation based on net MEAVs does not affect this underpinning cost structure for tariffs and no incidence effects are therefore anticipated. 3. Links to the Draft Water Resources Management Plan (dwrmp) As noted above, the Company s latest dwrmp was submitted as required to the Secretary of State for the Environment on 1 December 2017 and is being considered for formal consultation. Pre-consultation discussions took place with stakeholders, including Page 5 of 12
the Environment Agency and Customer Scrutiny Panel representatives in co-creation workshops over the summer of 2017. The options for sharing resources and for potential new suppliers have been considered in a co-ordinated way for the whole region through the Water Resources in the South East (WRSE) group. One new water trade to South East Water is already being developed and a second potential trade has been identified at a late stage in the WRSE modelling work. Again, as noted above, the dwrmp does not include any material supply side augmentations until 2058. Ofwat s Technical Guidance also recognises that the selection of future options to balance supply and demand is based on forward-looking Average Incremental Costs (AICs) and is not therefore influenced by allocations of any historic costs, including the legacy RCV allocation. Moreover, as no change in the balance of wholesale charges is expected to arise from the Company s proposed historic RCV allocation, the selection of future supply options is not affected. 4. Links to Bulk Supplies Ofwat s Technical Guidance notes that where bulk supply prices are related to average costs for components of water resource or network plus activities, the allocation of the RCV between the two price controls could have an impact on the cost associated with providing bulk supplies. As noted above, SES Water has only two bulk supply agreements one for c. 0.5 Ml per annum and the other for c. 34 Ml per annum) whose terms vary but, where applicable, reflect the savings in network operation and maintenance costs related to that supply. The proposed allocation of historic RCV is not expected to affect the balance of charges and therefore has no impact on the existing bulk supply agreement. 5. Roll Forward of Historic Net MEAV The start point for the Company s roll-forward of the historic MEAV at 31 March 2015, with no changes arising from changes in RAG definitions, has already been described. The roll-forward has then taken place in the two stages provided for in Table WS12. 1. A roll-forward to 31 March 2017 based on the allocations of capital expenditure for the years 2015-16 and 2016-17 included in the Company s audited historic cost regulatory accounts and annual performance reports. The procedure adopted was the same as that used in previous years when MEAV asset tables were required under the regulatory accounts guidelines. Disposals during this period are based on the assets disposed of from the historic cost register, as included in the audited historic cost regulatory accounts. Inflation has been applied using the RPI specified for the current cost accounts specified in the RAGs. Specifically, the year average RPI increases used are 1.56% for 2015-16 and 3.14% for 2016-17. Depreciation has been applied based on the asset lives allocated to individual assets in the MEA register, which are the same as those used to generate audited historic cost depreciation for the historic cost regulatory accounts. No reclassification or other adjustments have been considered necessary. 2. A roll-forward to 31 March 2020 at constant 2016-17 price base, reflecting a continuation of depreciation on the assets existing at 31 March 2017 on the same Page 6 of 12
basis as used for the roll-forward from 31 March 2015, and a forecast of additions and associated depreciation on additions in 2017-18 and the subsequent two years. The reliability of the forecast additions, their allocation between water resources and network plus, and their associated asset lives is lower than that attributable to the historic additions, for a number of obvious reasons. a. The mix of asset types and associated lives change during the design and delivery of all projects as pursuit of best value for money continues throughout the life of a project. The final mix of asset types and associated depreciation profile is not finally determined until late in project delivery. b. Depreciation only commences on asset take-over, which will vary not only with progress on individual projects, but with their scheduling within the programme for a particular year (and across years). c. Projects are subject to re-prioritisation before on-site work commences, as part of the continuous search for maximum customer benefit from the investment programme. This will have a greater impact on forecasts for 2018-19 and 2019-20 than on the current year (2017-18). No disposals, reclassification or other adjustments have been incorporated in the roll-forward post 31 March 2017. Annex 2 summarises the roll-forward for these forecast years. The impact of these uncertainties is not however considered material, as the proportion of total wholesale assets allocated to the Water Resources control only moves from 5.50% at 31 March 2017 to 5.24% at 31 March 2020. This result is in line with expectations as the water resources control assets have a higher proportion of longer-life assets than wholesale in aggregate and no major new additions to water resources assets are anticipated prior to 31 March 2020 (gross additions for the three forecast years being 1.8m or less than 2.5% of the net MEA asset value at 31 March 2017). 6. Revaluation of Net MEAV The Company has not undertaken a revaluation of all wholesale assets for the purposes of determining a basis for allocating the historic RCV between water resources and network plus controls. The revaluation undertaken for PR09 was a thorough revaluation of all assets based on the best engineering and operational expert knowledge available at the time, involved a major commitment of in-house resource and third party expertise, and gave rise to asset valuations that have subsequently proved reliable. In particular, they have been incorporated into audited current cost accounts without adjustment or qualification in any way, and have not given rise to any significant enquiries for either internal purposes or from third parties. On this basis, a major investment in a revaluation exercise for the sole purpose of allocating historic RCV between new price controls was not considered necessary. Although primarily focused on provision of an up to date asset condition assessment and overall valuation (for determining Current Cost Depreciation to be reflected in overall price limits), the PR09 valuation did address the allocation of assets across the value chain and can therefore be relied upon for the purpose now proposed. In line with the OFWAT asset inventory requirements, SESW tasked Faithful and Gould (F&G) with developing MEAV costs for all of their non-infrastructure assets (excluding IT and vehicles). In order to do this, F&G used a combination of top-down cost build-ups and estimates taken from curves trending categorised assets. Page 7 of 12
The overall valuation for non-infrastructure assets was undertaken for SES Water by Faithful and Gould (F&G). For Water Resources a site specific MEAV was based on quotes for the drilling activity needed to sink the borehole (depending on ground conditions). Ancillary items like pipework and the motor control centres were based on third party cost curves. Bough Beech Reservoir was revalued using current construction cost data. F&G also provided valuations using different inflation indices in order to provide some confidence in the revaluation figures. Atkins was subsequently asked to review the details of these cost revaluations using the inflated PR04 MEAV figures as a benchmark. 7. Potential for Reallocation at PR24 SES Water is satisfied with the allocation proposed in this submission, subject only to the uncertainties associated with forecast future expenditure (and its impact on depreciation and net asset values). Any requirement to undertake future MEA revaluation exercises in AMP7 or beyond may, of course, adjust the allocations proposed, but we have no expectation of having to carry out such an exercise in the foreseeable future. On the basis that allocations will be subject to review for 2017-18 actual expenditure and any revised forecasts arising from the on-going update to the Company s capital programme for the rest of the current price control period known by the time Business Plans are submitted in September 2018, the Company would not anticipate any new revision to allocations to be required at future price reviews except in response to regulatory or other externally driven changes. Approach to Assurance and Board Assurance Statement This submission is based on the Company s well-established procedures for assurance of all data, whether submitted to Ofwat, published or used for internal processes. The foundations are: Reliable and tested systems for the capture, processing and reporting of data relating to all aspects of company performance, including customer service, asset, and financial dimensions. Assembly, analysis and presentation of information by suitably qualified, trained and experienced staff working in a supportive and value-driven environment. Review by colleagues and senior staff not involved in the assembly and analysis of the information, providing context and testing assumptions against reasonable expectations in the light of wider business performance and the external environment. Audit by suitably qualified and experienced third parties, normally appointed after competitive tendering, to confirm accuracy and challenge preconceptions and management review processes. Governance by a highly-engaged Board, with suitable specialist skills to test the integrity of management controls and assess the reasonableness of conclusions and the acceptability of results against best practice from other contexts. This basic framework is assured through ISO accreditation (tested regularly by external assessors), independent external audit by financial auditors and engineering reporters, and assurance of control frameworks and management controls by shareholders own internal audit functions. For this particular submission the key assurance processes have been: Reliance on well-established systems for the assembly of asset information using techniques and processes that have been proven through rigorous external audit for previous regulatory accounts reports. Assessment of potential approaches and issues to be considered by executives with a broad regulatory knowledge and a full understanding of connections between different Page 8 of 12
aspects of accounting, reporting, regulatory and competitive factors needing to be taken into account in making decisions on approaches to be adopted. Oversight of data analysis and assembly by staff with a strong track record of controlling accounting and regulatory reporting processes and familiar with the latest developments in regulatory requirements. Review by executives not involved in data analysis and information assembly, testing for reasonableness and consistency with previous audited statements and wider business developments. External audit for accuracy and reliability of information reported and for the scope and level of compliance with reporting requirements. Governance under the personal supervision of an independent Board Non-executive Director with appropriate skills and experience to test and challenge assumptions, following consideration of the reporting requirements by the Audit Committee of the Board (on which Independent Non-executive Directors form the largest single group). These processes and key assumptions, uncertainties and sensitivities have been reflected in the Board assurance statement attached at Annex 1. Page 9 of 12
Annex 1 Board Assurance Statement on the Allocation of the Forecast RCV at 31 March 2020 to the Water Resources and Network Plus Wholesale Price Controls This assurance statement is provided as an annex to SES Water s submission on the allocation of the Company s forecast Regulatory Capital Value (RCV) at 31 March 2020 to the proposed Water Resources and Network Plus Price Controls to be determined by Ofwat for the period 2020 2025 under the 2019 Price Review (PR19). It should be considered in conjunction with the Company s submission of Tables WS12 and WS12b and the accompanying commentary. The submission has been prepared under the assurance processes applicable to all SES Water s regulatory submissions and performance reports. The Company s track record of performance reporting is strong and has been recognised as compliant with Ofwat s reporting requirements under the Company Monitoring Framework for both years upon which assessments have been carried out and reports issued. SES Water is proposing an unfocused allocation of RCV at 31 March 2020 based on the share of assets utilised by Water Resources and Network Plus business units, as measured by the net modern equivalent asset values forecast for those business units at 31 March 2020. Consideration has been given to the issues raised in Ofwat s Technical Guidance on the allocation, issued in January 2017, and the potential future changes in water resources management and expenditure requirements set out in the Company s draft Water Resources Management Plan. A review of the potential impact on the balance of charges between different customer segments has been undertaken and its conclusions reflected in the Company s submission. The asset allocation process has been based on that used successfully for many years by the Company for the production of current cost accounting statements and, where necessary, takes into account changes in the definition of business units. The accuracy of the arithmetical processes involved in asset valuation and allocations have been subject to third party assurance by the Company s external auditors, using staff familiar with the asset calculation and allocation processes used for production of audited regulatory statements. The submission has been subject to Board oversight and scrutiny, which for this submission involved: Consideration of the approach to be adopted, potential implications for the business and agreement of detailed governance by the Audit Committee of the Board; and Review of the final submission and associated third party assurance by the Chair of the Audit Committee, acting under power delegated by the Board. In signing this assurance statement, we draw attention to the following assumptions which have been incorporated into the submission: 1. That the Company s draft Water Resources Management Plan is accepted as submitted and the potential incorporation of an additional bulk supply to South East Water in 2035 has no material impact on RCV allocations Page 10 of 12
2. The impact of changes in the overall level and allocation of capital investment for the current year and 2018-19 and 2019-20 on the net asset value forecast at 31 March 2020. The sensitivity testing of this allocation described in the submission shows that the forecast makes an estimated 0.26% difference to the proportion of RCV allocated to the water resources control compared to the position at 31 March 2015 On this basis, we are content to provide assurance on behalf of the full Board of SES Water. John Chadwick Finance and Regulation Director Murray Legg Chair of the Audit Committee 30 January 2018 Page 11 of 12
Annex 2 Summary Calculations for MEAV Roll Forward 31 March 2017 to 31 March 2020 As of 31 Mar 2017 As of 31 Mar 2019 (in 2016/17 prices) Water Resources Network+ Grand Total ( ) Water Resources Network+ Grand Total ( ) Cost Cost Brought Forward 97,309,854 1,391,828,093 1,489,137,947 Brought Forward 100,397,053 1,455,272,361 1,555,669,414 Additions 719,737 22,497,095 23,216,832 Additions 519,902 23,773,098 24,293,000 Disposals -1,111,458-27,447,736-28,559,194 Disposals 0 0 0 RPI Adjustment 3,080,255 42,778,095 45,858,350 RPI Adjustment 0 0 0 As at 310317 99,998,388 1,429,655,546 1,529,653,934 As at 310319 100,916,955 1,479,045,459 1,579,962,414 Depreciation Depreciation Brought Forward 25,801,422 180,055,326 205,856,748 Brought Forward 28,269,197 189,488,005 217,757,202 RPI Adjustment 815,056 5,180,836 5,995,892 RPI Adjustment 0 0 0 Disposals -361,018-14,644,759-15,005,778 Disposals 0 0 0 Depreciation Charge 985,109 9,125,527 10,110,636 Depreciation Charge 1,079,764 10,415,351 11,495,115 As at 310317 27,240,569 179,716,930 206,957,498 As at 310319 29,348,961 199,903,355 229,252,316 Net Book Value 72,757,819 1,249,938,616 1,322,696,436 Net Book Value 71,567,994 1,279,142,104 1,350,710,098 Allocation Percentage 5.50% 94.50% 100.00% Allocation Percentage 5.30% 94.70% 100.00% As of 31 Mar 2018 (in 2016/17 prices) As of 31 Mar 2020 (in 2016/17 prices) Water Resources Network+ Grand Total ( ) Water Resources Network+ Grand Total ( ) Cost Cost Brought Forward 99,998,388 1,429,655,546 1,529,653,934 Brought Forward 100,916,955 1,479,045,459 1,579,962,414 Additions 398,665 25,616,815 26,015,480 Additions 943,030 21,262,206 22,205,236 Disposals 0 0 0 Disposals 0 0 0 RPI Adjustment 0 0 0 RPI Adjustment 0 0 0 As at 310318 100,397,053 1,455,272,361 1,555,669,414 As at 310320 101,859,985 1,500,307,665 1,602,167,650 Depreciation Depreciation Brought Forward 27,240,569 179,716,930 206,957,498 Brought Forward 29,348,961 199,903,355 229,252,316 RPI Adjustment 0 0 0 RPI Adjustment 0 0 0 Disposals 0 0 0 Disposals 0 0 0 Depreciation Charge 1,028,628 9,771,075 10,799,703 Depreciation Charge 1,134,861 10,754,356 11,889,216 As at 310318 28,269,197 189,488,005 217,757,202 As at 310320 30,483,822 210,657,711 241,141,533 Net Book Value 72,127,856 1,265,784,356 1,337,912,213 Net Book Value 71,376,164 1,289,649,954 1,361,026,117 Allocation Percentage 5.39% 94.61% 100.00% Allocation Percentage 5.24% 94.76% 100.00% Page 12 of 12