Société en commandite Gaz Métro Establishment of a Receipt Rate for Natural Gas R-3732-2010 RECEIPT RATE FOR NATURAL GAS Non official translation without prejudice Original : 2010.11.08 Gaz Métro – 4, Document 2 40 pages Presented to the Régie de l’énergie Application to the Régie de l’énergie Gaz Métro requests the Régie de l’énergie (“the Régie”) to authorize the creation of a new natural gas receipt rate, the terms and conditions of its application as well as methods for establishing the prices that will apply when investment requests are made. Gaz Métro is also requesting the Régie to fix certain prices applicable to volumes delivered at this time. The natural gas receipt rate will make it possible to recover the costs of the new investments required to extend Gaz Métro’s gas system and share some of the present distribution costs. 2 1 Connection and gas producing facilities model 3 Ratemaking Process Cost identification and allocation Annual rate reassessment (Pricing strategy) Receipt rate structure and conditions of service Method and establishment of initial applicable prices 4 2 Ratemaking Process Cost identification and allocation Annual rate reassessment (Pricing strategy) Receipt rate structure and conditions of service Method and establishment of initial applicable prices 5 Cost Identification and Allocation Respect of cost causality: Allocation of costs to those who generate them Costs related to new producer customers A – Costs related to the investments in connection pipelines B – Costs of existing gas system C – Distribution costs not related to the gas system D – Additional costs of using TCPL/TQM transmission system Cost allocation stages Functionalization between services and within the distribution function between consumer customers and producers Classification (direct allocation or related to volumes, number of customers, demand and/or revenues Allocation using the allocation factors 6 3 Cost Identification and Allocation Cost allocation Category A costs Initially, direct allocation among producers per receipt point Eventual revision of cost allocation method if consumer customers use the pipeline Category D costs – direct allocation to producers of one zone and allocation between producers according to volumes Categories B and C costs (common costs) A direct allocation of these common costs is not possible Functionalization of the existing distribution costs among consumer customers only and between producers and consumer customers Once the cost to be shared identified, classification and existing allocation factors related to these costs will be applied to allocate them between consumer customers and producer customers 7 Cost Identification and Allocation Cost allocation recapitulation Functionnalisation and cost allocation Functionnalisation (Distribution service) Allocation Producers Costs Costs related to investments in connection pipelines (A costs) Costs of existing distribution system Costs of transmission system (B costs) Other costs related to system (Frontage, meters, etc.) Distribution costs not related to gas system Costs not related to gas system to be shared (C costs) Other costs (EEGP, EEF, FV, CDP, etc.) Total existing distribution costs (budget 2008/2009) Additional costs of using TCPL/TQM transmission system (D costs) Investment request 241,8 M$ Consumers Yes No Yes Yes Non Yes Yes Non Yes Yes Yes No 48,3 M$ 193,5 M$ 295,2 M$ 160,7 M$ 134,5 M$ 537, 0 M$ Investment request 8 4 Ratemaking Process Cost identification and allocation Annual rate reassessment (Pricing strategy) Receipt rate structure and conditions of service Method and establishment of initial applicable prices 9 Receipt Rate Structure and Conditions of Service The established rates should recover the revenue requirements (i.e.) total costs plus a fair return on the rate base Gaz Metro aims to create a rate structure and conditions that: respect equity amongst customers and producers, in particular by minimizing cross subsidization Also ensure that the receipt rate aims revenue stability and a certain price stability are as simple as possible 10 5 Receipt Rate Structure and Conditions of Service Receipt rate Pricing at receipt point for each producer Allows recovery of categories A and C costs, ensures price stability and minimizes cross-subsidization amongst the producers Pricing at delivery points within the territory allows recovery of category D costs Pricing at delivery points outside the territory allows recovery of category B costs 11 Receipt Rate Structure and Conditions of Service Example of receipt rate schedule Receipt Rate Schedule Receipt Points Name MDO price (¢/m³/day) RP-1 RP-2 RP-3 RP-4 RP-5 1,40 0,50 0,74 0,77 0,29 Delivery Points Outside franchise Inside franchise vol. injected Consumption Unit price Unit price (¢/m³) zones vol. delivered vol. delivered (¢/m³) (¢/m³) 0,11 Consumption zone 1 0,027 0,70 0,03 Consumption zone 1 0,027 0,70 0,02 Consumption zone 1 0,027 0,70 0,14 Consumption zone 2 0,70 0,02 Consumption zone 2 0,70 Unit price 12 6 Receipt Rate Structure and Conditions of Service Application provisions of the receipt rate Revision of Maximum Contractual Capacity (MCC) Treatment of Maximum Contractual Capacity (MCC) overruns Treatment of differences between injected volumes and nominations Tolerance margin of 2% daily and 4% on a cumulative basis Fees for daily differences over 2% Fees when the daily balance of the cumulative account is over 4% Contract term, renewal and indemnity Composition of natural gas and calorific content Pressure Interruptions and curtailment of receipt of natural gas Changes to Conditions of Natural Gas Service and Tariff 13 Receipt Rate Structure and Conditions of Service The proposed pricing principles limit the risk of new assets related to the receipt of natural gas To ensure that each party bears a portion of the risk, Gaz Metro proposes the following conditions, including: 10 year contract period without any price reduction Compensation allowing the recovery of costs Applicable conditions to reducing of the CMC during the contract Establishment of 95% fixed revenue Possibility of a deposit requirement during the contract Deposit based on 12 months of service A retention period of 60 consecutive months Moreover, the receipt rate will benefit to all existing customers as a share of current costs will now be assumed by producers 14 7 Receipt Rate Structure and Conditions of Service Gaz Métro requests that the Régie approve the structure of the new receipt of natural gas rate Gaz Métro requests that the Régie approve changes to Conditions of Natural Gas Service and Tariff, including the text of the receipt rate 15 Ratemaking process Cost identification and allocation Annual rate reassessment (Pricing strategy) Receipt rate structure and conditions of service Method and establishment of initial applicable prices 16 8 Method and Establishment of Initial Applicable Prices Objectives Recovery of costs Importance of precise determination of initial prices Minimization of cross-subsidisation Minimization of potential price instability Challenges Category A and D costs will be known only when applying for an investment request Category B and C costs are existing costs but predictive allocation to producers is developed by making assumptions and approximations since producers are not yet part of the customer base 17 Method and Establishment of Initial Applicable Prices Initial prices applicable to receipt points Revenues associated to category A costs Method based on a calculation of revenue requirement Category A costs known at the moment of the investment request Proposal of an initial amortization period of 20 years (expected useful life of the assets) Weighted cost of capital used will be that which is used to fix current distribution rates Setting of initial price allowing to recover the costs (amortization, income taxes, return, etc.) over the amortization period 18 9 Method and Establishment of Initial Applicable Prices Initial prices applicable to receipt points Revenues associated to category C costs Prices set to generate revenues to allow recovery of costs allocated to each producer Predictive allocation to producers is developed by making assumptions and approximations since producers are not yet part of the customer base Gaz Metro requests the Régie to approve a ratio of 4% applicable on investments to allow the determination of an initial price by receipt point This method could be modified in subsequent rate cases according to the evolution of costs and adjustments to the allocation methods 19 Method and Establishment of Initial Applicable Prices Cost of service and revenues from rates $ Cost of service (A + C costs ) Revenues from rates (recovery of A + C costs ) Amortization period = Producer’s injection period Years 20 10 Method and Establishment of Initial Applicable Prices Initial prices applicable to receipt points Price example The global initial price of 1.50¢/m³ is split between: The initial MDO price fixed at 1.43¢/m³ The initial unit price by volume injected fixed at 0.07¢/m³ The global initial price of 1.50¢/m³ consists of: 0.36¢/m³ ($1.8M/ 500Mm³) for revenues associated to C costs 1.14¢/m³ for revenues associated to A costs Gaz Métro requests that the Régie approve the method for the establishment of prices at receipt points which will be applied in the case of an investment project 21 Method and Establishment of Initial Applicable Prices Initial prices applicable to delivery points within the territory to allow recovery of category D costs Category D costs known at the moment of the investment request Need to contract TCPL/TQM transportation evaluated according to total volumes injected in a consumption zone having the territory as delivery point Annual costs of TCPL/TQM additional transportation capacities divided by volumes injected in the consumption zone and deemed to be delivered within the territory Unit price applicable to this consumption zone Price billed for all volumes actually injected and having the territory as delivery point For example, the initial price could be 0.027¢/m³ for a given consumption zone 22 11 Method and Establishment of Initial Applicable Prices Initial prices applicable to delivery points within the territory to allow recovery of category D costs Gaz Métro requests that the Régie approve the method for the establishment of prices at delivery points within the territory which will be applied in the case of an investment project 23 Method and Establishment of Initial Applicable Prices Establishment of the initial price applicable to the delivery point outside the territory allowing to recover B costs Prices must generate revenues allowing to recover B costs allocated to producers Predictive allocation to producers is developed by making assumptions and approximations since producers are not yet part of the customer base Price applicable to volumes delivered outside the territory Gaz Métro requests that the Régie establish the applicable price of 0.70 ¢/m³ to volumes delivered outside the territory and this, in the course of the present application 24 12 Method and Establishment of Initial Applicable Prices Summary of initial prices applicable to receipt points and to delivery points Receipt rate Rate schedule Initial applicable prices (¢/m³) Receipt point - RPx A costs C costs Total Delivery point Within territory (D costs) Outside territory (B costs) 1.14 0.36 1.50 MDO price Unit price 1.43 0.07 0.027 0.700 25 Method and Establishment of Initial Applicable Prices Establishment of prices applicable to differences between injected volumes and nominated volumes The applicable prices below were calculated according to TCPL’s tolls in effect January 1, 2010 Prices Applicable to Daily Imbalances Difference Less than 2% 2% to 4% 4% to 8% 8% to 10% Over 10% Price ($/GJ) 0.000 0.328 0.819 1.229 1.638 Price (¢/m³) 0.000 1.241 3.103 4.655 6.207 Prices Applicable to Cumulative Differences Balance Less than 4% 4% to 6% Over 6% Price ($/GJ) 0.000 0.246 0.411 Price (¢/m³) 0.000 0.931 1.552 26 13 Method and Establishment of Initial Applicable Prices Establishment of prices applicable to differences between injected volumes and nominated volumes Gaz Métro requests that the Régie approve the method for the establishment of prices applicable to daily and cumulative imbalances as well as to establish these prices according to TCPL’s tolls applicable at the moment when the decision is issued 27 Ratemaking Process Costs identification and allocation Annual rate reassessment (Pricing strategy) Receipt rate structure and service conditions Method and establishment of initial applicable prices 28 14 Annual Rate Reassessment (Pricing Strategy) The prices applicable to all rates are reviewed annually in order to recover the required revenues Ratemaking strategy The ratemaking strategy applicable to producers must take into account the two following elements: Maintaining cross-subsidizing at its minimum: an annual review of the prices may be proposed according to the evolution of costs and results of the cost allocation study Stability of prices: the determination of an initial price as precise as possible allows to reduce potential rate variations in the case where an subsequent allocation of costs would result in prices significantly different from the prices initially established 29 Annual Rate Reassessment (Pricing Strategy) Prices at receipt points […] The prices could then be modified in subsequent rate cases depending on the evolution of costs (rate of return, income taxes, etc.) Prices at delivery points – within the territory […] Those prices could be modified in subsequent rates cases depending on the evolution of the TCPL/TQM transportation needs Prices at delivery points – outside the territory […] The price could be updated in subsequent rate cases 30 15 Annual Rate Reassessment (Pricing Strategy) Receipt Rate Pricing Strategy - Example of Price Evolution Establishment of prices Rate Case 2014 Applicable prices (RC2013 Ass. = initial prices) Initial applicable prices Applicable prices (RC 2014) (¢/m3) (¢/m³) Receipt point A costs C costs Total Delivery point Within territory (D costs) Outside territory (B costs) Cost allocation results (example) 1.14 0.36 1.50 1.14 0.36 1.50 1.05 0.30 1.35 ? ? ? 0.027 0.700 0.027 0.700 Reduction of TCPL cap. 0.65 0.015 ? Ratemaking Strategy Rate Case 2014 Correction of cross-subsidization (instability issue)? No correction of prices in order to maintain rate stability (cross-subsidization issue)? A combination of both and/or a spreading out on a few years 31 Annual Rate Reassessment (Pricing Strategy) Receipt Rate Pricing Strategy - Example of Price Evolution for year 21 Establishment of prices Initial applicable prices Rate Case 2034 Applicable prices (RC2013 Ass. = initial prices) (¢/m³) Receipt point A costs C costs Total Delivery point Within territory (D costs) Outside territory (B costs) Cost allocation results (example) Applicable prices (RC 2014) (¢/m³) 1.14 0.36 1.50 1.14 0.36 1.50 0.36 0.36 ? 0.36 ? 0.027 0.700 0.027 0.700 0.027 0.700 0.027 0.700 Ratemaking Strategy Rate Case 2034 Correction of cross subsidization? No correction of prices (cross subsidization issues)? 32 16 Ratemaking Process Costs identification and allocation Annual rate reassessment (Pricing strategy) Profitability analysis (marginal costs) Receipt rate structure and service conditions Method and establishment of initial applicable prices 33 Profitability Analysis and Impact on Rates At the moment, the profitability analysis allows the evaluation of the investment’s marginal profitability as well as the impact on rates depending on existing rates. No allocation of existing gas system costs is included in the revenue requirements In the case of the receipt rate, the prices are established to recover all the costs, i.e. the marginal costs (new costs) and a share of the existing costs Once these prices established, they will allow to recover more than the marginal costs (new costs) Higher IRRs than the prospective weighted cost of capital Reducing of rates for existing customers as soon as the first years (example: breakeven point of 1 year) 34 17 Profitability Analysis and Impact on Rates Cost of service and revenues from rates (assumption: gas delivered within the territory) Cost of service (A + C costs ) Revenues from rates (recovery of A + C costs ) $ Cost of service (A costs + duties) Breakeven point Amortization period = Producer’s injection period Years 35 Profitability Analysis and Impact on Rates Cost of service and revenues from rates (assumption: gas delivered within the territory) $ Revenues from rates (recovery of A + C costs ) Cost of service (A costs + duties) Decrease of rates Breakeven point Amortization period = Producer’s injection period Years 36 18 Ratemaking Process Costs identification and allocation Annual rate reassessment (Ratemaking strategy) Profitability analysis (marginal costs) Receipt rate structure and service conditions Method and establishment of initial applicable prices 37 Return on Two Concerns Expressed by the COGA Two concerns expressed by the COGA Deposits Particularly Article 8.1.3 which gives Gaz Métro the possibility to require a deposit during the course of a contract Differences between nominations and injected volumes Prices for daily imbalances between deliveries and nominations Prices applicable to cumulative differences 38 19 Article 8.1.3 « Deposits » of Conditions of Natural Gas Service and Tariff Article 8.1.3 stipulates that “The distributor may require a deposit when service is requested or during a contract from any customer subject to the receipt rate” The COGA evidence stipulates that this application is unfair Gaz Métro’s perspective The requirement of a deposit must be justified in all cases (article 8.1), including the case of article 8.1.3 If the Régie, following the COGA’s evidence, wishes not to retain Article 8.1.3, Gaz Métro sees no objection to producers being subject to article 8.1.2.2 39 Differences Between Nominated Volumes and Volumes Actually Injected D Producer customers In all cases Commercial transaction Carrier Direct Purchase Customers Others... Gaz Métro A Nominated volumes B Volumes actually injected A C Delivery C If B A Imbalances If A D Differences to be settled in accordance with the commercial agreement between the parties 40 20