Dr. Booth’s Responses to the Regie’s Information Request No.1 RATE OF RETURN ON EQUITY 2. References: (i) (ii) (iii) (iv) Item C-1-8, ACIG–6, document 1, pages 31-32, lines12-14 and 1-2 ; Item C-1-8, ACIG–6, document 1, page 4, lines 28-29 ; Item C-1-8, ACIG–6, document 1, page 5, line 1 ; Item C-1-8, ACIG–6, Append F, page 1, lines 14-17. Preamble: Reference (i) « The following table shows the stock market losses as of October 24, 2008 at the peak of the financial crisis. At that time from a US perspective year to date the best performing stock market was Japan’s which was only down 35%, the worst among the majors was Hong Kong at 58%, not counting Russia’s, which was off 75% before they closed the market. Globally about $14 trillion in wealth had disappeared in a few weeks. » Reference (ii) « The US credit crunch exacerbated a normal cyclical recession and caused the biggest stock market crash for 70 years and fears of a Great Depression II. » Reference (iii) « This stock market crash has been traumatic. » Reference (iv) « Like the Canadian data in Appendix E including 2008 data dramatically lowers the experienced market risk premium since the S&P500 total retum for 2008 was - 37% while the decline in the long US Treasury bond yield from 4.35% to 3.18% generated very large capital gains from holding US govemment bonds.» [emphasis added] Questions: 2.1 Given the stock market correction of 2008, how are such events taken into account by investors in their yield expectations? Do you believe that investors in 2009 require a premium for higher or lower risk than in 2007? Please justify your answer. 2.2 As outlined in Appendix F, the combination of the worst stock market since the „30s and the exceptional increase in the bond market “dramatically” reduces the premium for market risk estimated using the historical average. Should we, on an exceptional and temporary basis, exclude 2008 data from the historical average to better reflect the current requirements of investors with respect to the risk premium in the market? Please comment. R-3690-2009 ACIG-6 – Doc. 2 Page 1 of 15 Answer 2.1 From basic financial theory Dr. Booth believes that risk premiums are timevarying: they tend to increase during recessions and fall during booms as both the level of wealth and confidence varies. One indication of this is the flow of money into and out of mutual funds as the “small” retail investor enters and leaves the market. However, the markets are now dominated by institutional and not retail investors making inferences based on an individual‟s psychology etc perhaps less relevant than in the past. To illustrate Dr. Booth provides a recent strategy report from the Royal Bank (jul29sw.pdf) which focuses on the increased “risk appetite” of the market over the last three months since recovery set in during March 2009. The first paragraph of that report states: This indicates that whereas there was extreme risk aversion in the market (avoidance of risk at all costs) prior to March 2009, since then the risk appetite has increased significantly as investors have piled into the riskiest stocks and been amply rewarded. In fact the recovery from March 9, 2009 has been one of the fastest and largest recoveries in history as investors have accepted that the worst of the recession is over and are afraid of missing the continuing rally in the stock market. For example CNBC in the US stated on August 7, 2009: R-3690-2009 ACIG-6 – Doc. 2 Page 2 of 15 Stocks Surge To New '09 Highs Posted By:Lee Brodie STOCKS SURGE TO NEW ’09 HIGHS Afraid of missing the next leg higher, investors poured back into stocks on Friday sending the S&P 500 [.SPX 1010.48 13.40 (+1.34%) to a new high for 2009. A better-than-expected jobs report fueled hopes of an economic recovery and suggested the recent market run-up was on solid ground. For the week, the Dow was up 2.2 percent, the S&P 500 was up 2.3 percent and the Nasdaq was up 1.1 percent. With the bulls large and in-charge how should you be positioned? Considering the market action, I think we could easily see 1050 on the S&P, muses Steve Grasso. The bullishness was generated by the part of the jobs report that showed manufacturing was improving, adds Joe Terranova. Investors liked the strength and that’s what sent stocks higher. There’s also a lot of put protection in the market, says Pete Najarian. That actually gives investors more confidence (because losses are limited) and they become okay with taking more risk. Dr. Booth believes that this crisis was caused by poor regulation of US financial institutions that generated a global credit crunch, which until Lehman Brothers was allowed to fail, no-one anticipated. However, in many ways financial problems are easier to solve than operating problems, since it is mainly a question of accepting write offs on asset values, which has now largely happened. Since the US guaranteed their largest banks and stress tested them, the market has rebounded very significantly and the real economy will follow with a lag, In Dr. Booth‟s judgment risk aversion was at elevated levels from September 2008-March 2009, but that it is now rapidly returning to normal levels as is also confirmed by bond market data. Dr. Booth would judge the current situation as a normal recessionary one, rather than the fear from September 2008-March 2009 that we could be in a Great Depression II. As such he would not adjust his market risk premium estimate for normal cyclical events. Given the difficulty of estimating the level of the market risk premium Dr. Booth believes that estimating changes in it is hazardous. Answer 2.2 No. The data is what the data is. We should no more exclude 2008 than the previous five years when the return on the TSX was 9.83%, 17.26%, 24.13%, 14.48% and 26.72% for an average of 18.50%, which is clearly above market expectations and excessive. R-3690-2009 ACIG-6 – Doc. 2 Page 3 of 15 However what we should do is exercise judgment. Dr. Booth did not adjust his market risk premium estimate of 5.0% downwards to reflect 2008 data and in fact has increased the “zone of reasonableness” to take into account Fernandez‟ survey of Canadian academics that placed the median market risk premium in Canada at 5.1% with the vast majority at either 5% or 6%. So far year to date the TSX has earned 21.1% and the S&P500 11.87%, Dr. Booth believes that when 2009 data is added, the estimates of the market risk premium will increase back to the 5.0-6.0% range that most academics believe is reasonable. So rather than adjust “hard” numbers by selectively ignoring some, Dr. Booth suggests that the Regie rely on his professional judgment and that of Canadian Professors of Finance as indicated in Fernandez‟s survey. 3. References: (i) (ii) (iii) (iv) Item C-1-8, ACIG–6, document 1, page 42, lines 25-26; Item C-1-8, ACIG–6, document 1, Schedule 12; Item C-1-8, ACIG–6, document 1, page 43, lines 10-13; Item C-1-8, ACIG–6, document 1, page 78, lines 21-23. Preamble: Reference (i) « Schedule 12 shows spreads using the A and BBB spread data from the Scotia Capital long bond indexes.» Reference (ii) The graph shows the differences in yield of long-term corporate bonds rated A and BBB, versus long-term federal bonds since 1988. Reference (iii) « Second and more important is the fact that what is unique during the current period is the dramatic increase in spreads experienced by A rated companies. During previous recessions and crises A spreads reached 150 basis points, whereas in this crisis they reached 350 basis points before their recent precipitous decline. » Reference (iv) « Regardless the panic in the bond market has passed and spreads are now back to the level that are typical of serious recession rather than the levels of a few months ago that suggested that the “sky is falling.” » Questions: 3.1 Please provide historical data, dating back at least to 1960 (to cover the most possible economic cycles) and in the form of an Excel file, concerning the yield rates of Canadian long-term corporate bonds rated A, and the yield of Canadian federal government bonds with the same maturity (10, 20 or 30 years). Please calculate and provide spreads, calculate and provide the average yield spread and the standard deviation for the whole period. Please describe in graphic form the spreads, the R-3690-2009 ACIG-6 – Doc. 2 Page 4 of 15 historical average of these spreads for the whole period, and indicate the limits established by more or less one and two standard deviations. 3.2 Please provide the same historical data, dating back at least to 1960 and in the form of an Excel file, concerning the yield rate of U.S. long-term corporate bonds rated A, and the yield of U.S. federal government bonds with the same maturity (10, 20 or 30 years). Please calculate and provide spreads, calculate and provide the average yield spread and the standard deviation for the whole period. Please describe in graphic form the spreads, the historical average of these spreads for the whole period, and indicate the limits established by more or less one and two standard deviations. 3.3 Please provide historical data supporting the assertion that the yield spreads are now back to levels typical of a serious recession. Specify and show what these spreads were during the recession of 73-74, 81-82 and any period comparable to the current situation. Please comment. Answers 3.1& 3.3 Data provided as far back as is available in electronic format, which is December 1979. Dr. Booth is aware that the Scotia Capital “A” bond yield data actually goes back to August 1976 or another 3 years or so, but since that period does not cover a recession he has not sought out that data to manually transcribed it. The average spread is 102 basis points (bps) with a standard deviation of 45.2 bps and range from a minimum of 35 bps to a maximum of 370 bps. A two standard deviation range around the average would be +/- 90 bps. The current spread of 177 is slightly less than that reached in May 1982 of 183 bps and within the +/- two standard deviation range where the limit would be 192 bps. This confirms Dr. Booth‟s statement that the yield spreads are back to levels typical of a serious recession and down from the recent high of 370 bps which indicated a “sky is falling” scenario. Note that normally A spreads peak at lower levels than the 183 bps of May 1982. In the 2001-2 slowdown the peak was 150 bps and in the period 1989-94 122 bps. A graph of the spreads follows and is in the Excel file. A Spreads since 1980 400 350 300 250 200 150 100 50 R-3690-2009 12/31/2008 12/31/2007 12/31/2006 12/31/2005 12/31/2004 12/31/2003 12/31/2002 12/31/2001 12/31/2000 12/31/1999 12/31/1998 12/31/1997 12/31/1996 12/31/1995 12/31/1994 12/31/1993 12/31/1992 12/31/1991 12/31/1990 12/31/1989 12/31/1988 12/31/1987 12/31/1986 12/31/1985 12/31/1984 12/31/1983 12/31/1982 12/31/1981 12/31/1980 12/31/1979 0 ACIG-6 – Doc. 2 Page 5 of 15 Answer 3.2 Dr. Booth has not used US interest rate data in his testimony. However, in order to be helpful he has sought out the following data back to 1947: US government long term bond yields (FYGLT) and A rated (Moody‟s) corporate bond yields (FYAC). Dr. Booth is not familiar with either of these series, but they are from the Citibank Data Bank, which he believes to be reliable. Unlike the Canadian data which is weekly this data is monthly so should be slightly less volatile. The average spread since 1947 is 127 bps with a standard deviation of 69 and a range of 33-385 bps. For the same period 1980-2009 the average is 152 bps and a standard deviation of 64 bps and a range of 76-386 bps. A two standard deviation range based on the same period is +/128bps. The latest spread data in the date bank is May 2009 which is 243 bps, which is within the upper limit of the US average of 152 bps +128 bps or 280 bps. A graph of the US spread data follows and is also in the Excel file US A Spread 450 400 350 300 250 200 150 100 50 2008M05 2006M06 2004M07 2002M08 2000M09 1998M10 1996M11 1994M12 1993M01 1991M02 1989M03 1987M04 1985M05 1983M06 1981M07 1979M08 1977M09 1975M10 1973M11 1971M12 1970M01 1968M02 1966M03 1964M04 1962M05 1960M06 1958M07 1956M08 1954M09 1952M10 1950M11 1948M12 1947M01 0 Dr. Booth is cautious about using this US data since he is not familiar with it, but there are some striking differences compared to the Canada data: a) The recession of the early 1990s hardly shows up which confirms his discussion that the Canadian recession was more severe due to adjustments to Free Trade; b) The US spike in the early 1980s recession is more serve than in Canada where the A spread hit 383 bps; c) The significant recession of the early 1970s and the panic of 1973 following the Arab Israeli war clearly show up in A spreads spiking to 251 and 313 bps respectively. 4. Reference: Item C-1-8, ACIG–6, document 1, page 47, lines 7-10. Preamble: « Overall this Statistics Canada ROE data reinforces the aggregate profitability data that the top of the business cycle was in 2007. For the whole period, 1988-2008 the average Statistics Canada ROE for Corporate Canada was 9.1% and the median 9.88%. What this means is that the average firm in Canada does not earn the level of ROE requested by Gaz Metro of 12.39%; » R-3690-2009 ACIG-6 – Doc. 2 Page 6 of 15 Questions: 4.1 Please describe the type of companies, business sectors covered and not covered, the size and the total number of companies covered by the series of Statistics Canada used for ROE. 4.1 Please explain how this series is representative of the composition of the S&P/TSX generally used as a representative of the Canadian stock market. 4.2 Please compare the ROE of the S&P/TSX (and its predecessor, TSE300) with those published by Statistics Canada for the period 1987-2008. Answer 4.1 Dr. Booth‟s understanding is that this data comes from tax return data covering all companies operating in Canada both public and private. It is obtained from the Canadian Economic Observer where Statistics Canada divides Cansim series V634673 by Cansim series V634628. The series are described as: v634673 Canada; Total, all industries (excluding management of companies and enterprises and other funds and financial vehicles); Net profit, seasonally adjusted (Dollars) v634628 Canada; Total, all industries (excluding management of companies and enterprises and other funds and financial vehicles); Total, equity (Dollars) Answer 4.2 Dr. Booth does not claim that it is comparable to the S&P/TSX Composite. He claims that it is representative of Corporate Canada since that is presumably why Statistics Canada calculates it and presents it as a core statistic in the Canadian Economic Observer. Which is more representative is difficult to argue either way; a strong case can be made that the firms in the TSX60 at least are large powerful firms with market power and should not be compared to the ROE of regulated utilities that are regulated to remove this market power. Note Dr. Booth presents such data to show where we are in the business cycle and what is typical; not as a basis for his recommendations. Answer 4.3 Dr. Booth does not have access to the data going that far back. Normally corporate data is only available on a rolling ten year window for current firms so checking for the TSX back to 1987 and for firms that no longer exist is a major exercise. However, in FP Full coverage ROE.xls is a file of all the current firms for which the Financial Post has full coverage for the last ten years. The following graph is of the Statistics Canada data for the same period as for the average and median of the FP data. Clearly the average is “pulled down” by the skewed nature of some of the ROEs, so that the median is a better statistic. The correlation between the FP median ROE and the Statistics Canada data is 0.95, but the median ROE for the FP firms is consistently lower than that for the Statistics Canada data. Consequently Dr. Booth has no reason to believe that the statisticians at Statistics Canada have made any mistakes or that their ROE data is “too low” or unrepresentative of the ROE of Corporate Canada R-3690-2009 ACIG-6 – Doc. 2 Page 7 of 15 ROE for Corporate Canada 25.00 20.00 15.00 10.00 5.00 0.00 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 -5.00 -10.00 AVG 5. References: (i) (ii) (iii) Med StatsCan Item C-1-8, ACIG–6, document 1, page 51, lines 27-28 and table; Item C-1-8, ACIG–6, document 1, page 53, note 12; Item B-24, Gaz Métro, Responses to DDR #1, pages 95-96. Preamble: Reference (i) « To illustrate, the betas for the major Canadian UHCs as well as the average (utility beta) for each of the 5-year periods ending 1985 through 2008 are as follows: » Table of betas of 10 utility companies. Reference (ii) « Betas are estimated over five year periods of monthly data so the 1985 estimate covers the period 1980-1985» Reference (iii) In response to question 26.2 Gaz Métro provides unadjusted β. Questions: 5.1 The β of the companies provided by Dr. Booth on page 52 are significantly lower than nonadjusted β of Bloomberg, as furnished in response to the request for information made to Gaz Métro, question 26.2. Please explain the difference. 5.2 Since β calculated from monthly data may not capture all the movements of securities and the market as β calculated from weekly data, please indicate whether all β provided by Dr. R-3690-2009 ACIG-6 – Doc. 2 Page 8 of 15 Booth for the period 1985 to 2008 are calculated from monthly data. If yes, please explain why Dr. Booth has preferred to use the monthly β rather than unadjusted Bloomberg β. Answer 5.1 Dr. Booth does not use Bloomberg betas, but as far as he is aware Bloomberg adjusts the actual betas by averaging them with the overall or grand mean for the stock market as a whole which is 1.0. The normal justification for this is an article by Marshal Blume in the Journal of Finance (June 1975) who put the adjustment down to measurement error. The essential argument is that if you don‟t know anything about a stock then the best guess is that its beta is 1.0, that is, the grand mean. If you then observe a beta of 1.5 then that could be caused by either permanent effects or a temporary event causing measurement error. If it is the latter then the beta is an over-estimate and it will revert to the grand mean of 1.0. Hence the adjustment by weighting what could be an over estimated beta of 1.5 with the prior estimate of 1.0. The opposite occurs with a beat of 0.50. However, in providing testimony before the Regie we are not dealing with a randomly chosen stock about which we know nothing: we are dealing explicitly with utilities about which we know a lot, so the Blume justification for adjusting betas has no validity since there is no expectation that they will revert to 1.0. Instead the “prior” belief, if we know the stock is a utility, is not that its beta is 1.0 but that it is the grand mean of all the utility betas which is about 0.50. This is the Gambola and Kahl paper cited by Dr. Booth in footnote 14 (Gombola and Kahl, “Time series properties of utility Betas,” Financial Management, 1990). Adjusted betas, like Bloomberg‟s, have been rejected by other regulatory bodies such as the NEB in its TQM decision where they stated on page 27 “The Board does not believe that TQM has demonstrated that utility betas ultimately revert to one, an assumption on which adjusted betas rely.” Answer 5.2 This is a question of what is the correct interval over which to measure risk. The question assumes that it is weekly, however, this depends on the investor‟s investment horizon and Dr. Booth is not aware of any evidence that indicates that investors use a weekly time horizon in investment planning. He would hypothesize that most investors use at least a monthly horizon for when they receive their statements or more likely a quarterly horizon when institutions are evaluated; what happens in between may, or may not, matter if it is not “recorded.” Dr. Booth uses monthly data since this is the way that almost all stock data is recorded in the major data tapes. The standard way of estimating betas is then to use five years of monthly observations since 60 observations gives reasonable statistical precision and balances precision with the fact that betas may change for economic reasons. The monthly interval is because the original data was manually collected by the Cowles Foundation going back at least to 1861 in the United States. This price data can then be matched up with dividend payments to get monthly total returns. As well as monthly data more recent data has been available on a daily basis so that researchers can examine how the stock market reacts to corporate events such as a dividend cut. R-3690-2009 ACIG-6 – Doc. 2 Page 9 of 15 However, he does not believe that investors operate on a daily investment horizon. He is not aware of vendors selling weekly series for stock prices. In terms of Dr. Booth‟s reliance on his own estimated betas, he does this since he knows the source of the data and that they are calculated in the standard way. If he were to unadjust Bloomberg‟s betas that assumes that their original betas were estimated correctly from correct data and he has no reason to believe that either assumption is correct. The same holds if he were to use Royal Bank betas, Value Line betas, Yahoo betas, Merrril Lynch betas or anyone else‟s betas. 6. References: (i) (ii) (iii) Item C-1-8, ACIG–6, document 1, page 69, lines 18-19 and 21-24; Item C-1-8, ACIG–6, document 1, page 70, lines 17-18 and note 23; Item C-1-8, ACIG–7, document 1, Exhibit MPG-4, p.2. Preamble: Reference (i) « No, regulated firms should be allowed to recover their issue costs in the allowed return in the same way that issue costs attached to debt are included in the embedded debt cost. » « These costs are made up of two kinds: the out of pocket reimbursement of expenses plus the under pricing of a new issue to ensure a successful offering. Overall these costs run up to 5.0% for a normal issue, although they can be smaller for larger issues since there are economies of scale. » Reference (ii) «Once the tax deductibility of some of these costs is considered, a true "flotation or issue cost" allowance of less than 44 basis points is reasonable plus the out of pocket expenses.» « Note that with 5% issue costs, the idea is that the stock should sell at a market to book ratio of 1.053, so that it will net out book value on any new issue. With utility market to book ratios vastly in excess of 1.052 it is difficult to rationalise any flotation cost allowance, since it is unlikely that there will ever be any dilution. » Reference (iii) The "Dividend Metrics" table gives on line 12 the average payout dividend ratio, ranging from 55.2% to 59.6% between 2004 and 2008, with an average of 57.8%. This suggests that over 42% of profits are reinvested and are reflected in shareholders' equity as "retained earnings". Question: 6.1 Does the calculation of issue costs (flotation cost) presented by Dr. Booth take into account the fact that a large part of shareholders' equity is normally made up of retained earnings and not the result of issuing shares? Please comment. R-3690-2009 ACIG-6 – Doc. 2 Page 10 of 15 Answer 6.1 Yes. As Dr. Booth discusses in his testimony (pages 69-71) the higher the dividend yield the more a firm relies on raising new equity to maintain its financial structure and as a result the higher the flotation cost adjustment. Conversely the lower the dividend yield the more retained earnings and the lower the flotation cost adjustment. As Dr. Booth goes on to say the major reason for this adjustment is to make sure the firm “nets out” book value in a new share offering so there is no dilution. To the extent that shares sell substantially above book value the motivation for any issue cost allowance is weak. However, Dr. Booth always recommends 50 bps as a generic allowance since this seemed to evolve out of a compromise. 7. Reference: Item C-1-8, ACIG–6, document 1, page 78, lines 14-18. Preamble: Reference (i) « For the above reasons my recommendation is to ignore the impact of any increases in bond yield spreads on the ROE, since they do not indicate that the risk premium attached to investing in bonds has increased. In my judgement a significant part of the increase in “A” spreads was caused by the major banks liquidating their bond inventories in order to raise capital and survive, particularly in the US. » Question: 7.1 Is your analysis based on an analysis of the data? If so, please identify your sources regarding the settlement of corporate bonds, specify the magnitude of sales of corporate bonds by rating (AAA, AA, A, BBB) by the Canadian and U.S. banks during the 4th quarter 2008 and 1st quarter of 2009 and please put these volumes into perspective with the volumes of transactions of previous years. Answer 7.1 answer: R-3690-2009 When Dr. Booth asked Mr. Engen of BMO for the data he was given the following ACIG-6 – Doc. 2 Page 11 of 15 The fact is that the only people who have the required data are the banks, and here even Scotia Capital has stopped providing basic corporate bond yield data for publication in the Bank of Canada Review. Quite amazingly after Mr. Engen refused to provide the data he asked Dr. Booth for it! Dr. Booth‟s analysis is based on the press reports of the Herculean efforts used by the Federal Reserve Board in the US to try and create liquidity in the markets after they froze in mid September and discussions with investment bankers. As he notes in his evidence these spreads came down after the stability of the banking system had been assured which points to the pivotal role played by the investment banks as market makers in the bond market. Also note that it is not volume per se but how the transaction is made that affects liquidity. A $10 million bond trade might have been made instantaneously in the summer (2008) because a bank was willing to buy it and keep it on its books to sell later. However, after Lehman the same bank might only do an agency trade, that is, try and match up the $10 million sale with other institutions willing to buy, so the trade might have taken hours if not days because the bank was unwilling to take the risk itself in a principal transaction. Either way the $10 million would be traded but the liquidity in the latter transaction is much lower and the costs higher. 8. Reference: Item C-1-8, ACIG–6, Append E, page 3, lines 24-29. Preamble: Reference (i) « In Schedule 1 are the results of a study of realised Canadian risk premiums over the longest time period for which there is data available. The data is taken from an annual "Report on Canadian Economie Statistics, 1924-2007," March 2008, compiled on behalf of the Canadian Institute of Actuaries extended to include 2008 data. Over the entire period 1924-2008 an R-3690-2009 ACIG-6 – Doc. 2 Page 12 of 15 investment in equities would have eamed an average total rate of retum of 10.38% using the OLS estimate, 9.64% using the geometric mean estimate, and 1l.31% using the arithmetic retum estimate. The corresponding return estimates for the long Canada bond are 5.68%, 6.22% and 6.55%, producing corresponding market risk premium estimates of 4.70%, 3.42% and 4.76%. » Questions: 8.1 Please provide in the form of Excel spreadsheet the data used to calculate the historical averages in Canada and the results of these calculations. 8.2 Please provide in the form of Excel spreadsheet the same data used to calculate the historical averages for the U.S. market and the results of these calculations. 8.3 Please specify in the context of increasing integrating of North American financial markets, what weight should be given to Canadian and American statistics, respectively. Answers 8.1 & 8.2 Data provided as Booth Regie 8.xls Answer 8.3 Dr. Booth‟s estimates of the market risk premium are not based on market integration. As his Appendix D shows as markets become more integrated market risk premia normally fall since there is increased diversification and a reduction in risk. This is one of the most basic results in finance: that diversification lower risk and with it risk premia. It takes pathologically extreme values to get the market risk premium to increase as markets become more integrated. This applies to the historic US estimates as well as the Canadian ones: theoretically they all over-estimate the market risk premium going forward. However, Dr. Booth makes no adjustments to his market risk premium estimates for the lower risk that results from better diversified Canadian portfolios. Dr. Booth prefers to see US market risk premium estimates as simply another set of estimates from another market and then analyse why they might be similar to Canada. In this regard he points out that US market risk premium estimates are about 1.0% higher than in Canada split 50:50 with lower bond returns and higher equity returns. Given the role of the US dollar as the major reserve currency you might expect US equity returns to be about 0.50% higher than US bond returns or alternatively the Canadian returns to be lower by the same amount. Dr. Booth would judge the US equity market to be riskier than that of Canada so the higher US market risk premium makes sense. This assessment is borne out by Fernandez‟ survey of finance professors worldwide where the median US finance professor pegs the market risk premium at 6.0% whereas the Canadian one puts it at 5.1%. Dr. Booth would accept that the market risk premium is most likely between 5.06.0% but recommends 5.0%. R-3690-2009 ACIG-6 – Doc. 2 Page 13 of 15 So Dr. Booth places most weight on Canadian statistics and uses US data as a check. It is not possible to come up with any simple arithmetic weights. 9. Reference: Item C-1-8, ACIG–6, Appendix H, pages 31 and 32, Schedules 1 and 2. Questions: 9.1 Please provide, from the data available for each company of your samples, the structure of authorized capital, the authorized returns on an equity base and the bonuses authorized with the date of decision and the total returns achieved. 9.2 Please provide an analysis of the volatility between the yield authorized and the yield realized for the companies of your samples. Answer 9.1 Unfortunately it is not possible to provide all the data since the source of the data was information requests asked of the different companies at different points in time. As far as Dr. Booth is aware the TCPL associated companies were not on incentive regulation until 2005 and the class 1 pipes all had 30% common equity ratios until the Mainline successively got this increased to 33% in 2001 and 36% in 2004 in hearings before the NEB and then 40% in a settlement with the shippers, the terms of which are confidential. His understanding is that Foothills (including the BC System) is now also on 36% common equity achieved through settlement. For the other utilities Enbridge Gas Distribution was on 35% common equity until it was increased to 36% in 2006, while Union Gas was on 29% until it moved to flow through taxes and then merged with Centra Gas Ontario and was increased to 35% and then 36% in 2006. In 2005 the BCUC increased Terasen Gas Utility‟s common equity ratio from 33% to 35%. Answer 9.2 Dr. Booth has done the analysis but does not believe it makes any sense. For example in the following tables the Mainline Foothills and TQM all have similar variability in the earned minus allowed of 0.23. However, Foothills had no variation at all until it negotiated an R-3690-2009 ACIG-6 – Doc. 2 Page 14 of 15 incentive deal with the shippers so that for 2005-7 it has significantly over-earned, but this can not be regarded as risk. Risk is the probability of incurring harm and over-earning is not anyone‟s definition of harm! Similarly EGDI and Union have high variability since they consistently overearn while TGI has the highest due solely to 1992 when the company was still in its formative years having been created out of the old Inland Natural Gas the gas assets of BC Hydro. Mainline Foothills ANG TQM EGDI UNION TGI GMI 0.09 0 0 1.12 0.35 -0.10 0.15 0 0 0.19 0.16 -1.00 0.18 0 0 0.22 0.28 0.70 0.06 0 0 0.25 2.13 1.80 -0.09 0 0 0.3 0.89 0.39 -0.92 0.04 0.31 0 0 0.4 1.01 0.37 0.03 -0.22 0.58 0 0 0.58 1.27 0.77 0.80 0.04 0.48 0 0 0.27 1.50 1.26 1.02 0.4 0.42 0 0 0.11 1.67 0.70 -0.59 0.34 0.06 0 0 0.36 1.26 0.49 1.45 0.58 0.09 0 0 0.06 1.10 0.16 1.25 0.34 0.11 0 -2.75 0.6 0.49 1.50 0.13 0.78 0.42 0 0 0.27 2.15 2.41 0.90 1 0.39 0 -1.58 0.42 3.45 2.13 0.81 0.93 0.27 0 0 0.28 0.97 0.83 0.31 2.02 0.2 0.68 0 0.46 -0.11 0.04 0.65 -0.41 0.11 0.71 0.67 0.43 0.28 0 0.21 0.23 0.75 0.24 0.90 0 0 -3.19 0 0 0.82 0.89 1.28 0.55 HBdocs - 6862012v1 R-3690-2009 ACIG-6 – Doc. 2 Page 15 of 15