Independent Engineer’s Report on the Asset Adjustment Process of: OtagoNet Joint Venture 1 November 2011 Independent Engineer’s Report on the Asset Adjustment Process of: OtagoNet Joint Venture 1 November 2011 Level 3 12-16 Nicholls Lane Parnell 1149 PO Box 9806 Auckland Tel: +64 9 928 5500 Fax: +64 9 928 5501 Web: www.skmconsulting.com COPYRIGHT: The concepts and information contained in this document are the property of Sinclair Knight Merz Pty Ltd. Use or copying of this document in whole or in part without the written permission of Sinclair Knight Merz constitutes an infringement of copyright. LIMITATION: This report has been prepared on behalf of and for the exclusive use of Sinclair Knight Merz Pty Ltd’s Client, and is subject to and issued in connection with the provisions of the agreement between Sinclair Knight Merz and its Client. Sinclair Knight Merz accepts no liability or responsibility whatsoever for or in respect of any use of or reliance upon this report by any third party. The SKM logo trade mark is a registered trade mark of Sinclair Knight Merz Pty Ltd. OtagoNet’s Asset Adjustment Process Contents Executive Summary 1 1. Introduction 3 1.1. 1.2. 3 4 Background Processes 2. Information Provided by OJV 5 3. Consideration of RAB Adjustments 6 4. 3.1. 3.2. Load Control Relays Correct Asset Register Errors 3.2.1. 3.2.2. 3.2.3. 3.2.4. 3.2.5. 3.2.6. 3.2.7. Value Modified: Reclosers Value Modified: 11kV cables and LV cables Assets Omitted in Error: Distribution Substation Fuses Assets Omitted in Error: Regulating Transformers Assets Omitted in Error: Kiness Structure Assets Omitted in Error: Streetlight ICPs Assets Omitted in Error: Distribution Substation MDIs 3.3. Reapplication of Asset Multipliers 3.3.1. 3.3.2. 3.3.3. 3.3.4. Re-apply an existing multiplier: Remote multiplier applied to Zone Subs Re-apply an existing multiplier; remote multiplier region extended Re-apply an existing multiplier; rugged multiplier region extended Re-apply a modified multiplier: Rugged 3.4. 3.5. Re-apply Optimisation and/or Economic Value Test Other Issues Summary 6 7 7 8 8 9 9 9 10 10 11 12 15 18 19 19 21 Appendix A Table Summary of Asset Value Adjustments: Schedule A4 22 Appendix B OJV’s Instructions to Engineer 23 Appendix C Signed Statement by Engineer 24 Appendix D Additional Information 25 SINCLAIR KNIGHT MERZ PAGE i OtagoNet’s Asset Adjustment Process Document history and status Revision Date issued Reviewed by Approved by Date approved Revision type 0 25 May 2011 D Healy S Wightman 25 May 2011 Draft 1 26 May 2011 D Smith S Wightman 26 May 2011 Final 2 28 June 2011 S Wightman S Wightman 28 June 2011 Update subsequent to Commerce Commission comments. 3 1 Nov 2011 S Wightman S Wightman 1 Nov 2011 Update requested by OtagoNet Distribution of copies Revision Copy no Quantity Issued to 0 Electronic 1 Terry Jones 1 Electronic 1 Terry Jones 2 Electronic 2 Terry Jones 3 Electronic 2 Wayne Stronach / Ken Forrest Printed: 1 November 2011 Last saved: 1 November 2011 12:20 PM File name: I:\ZPINA\Projects\ZP01068\Deliverables\ZP01068 - OtagoNet Engineering Report Updated 1-11-11.docx Author: Richard Fairbairn Project manager: Richard Fairbairn Name of organisation: OtagoNet Joint Venture Name of project: Adjusted 2004 RAB Name of document: Independent Engineer’s Report on the Asset Adjustment Process of OJV Networks Document version: Version 3 Project number: ZP01068 SINCLAIR KNIGHT MERZ PAGE ii OtagoNet’s Asset Adjustment Process GLOSSARY EDB Electricity Distribution Business DRC Depreciated Replacement Cost EDB IM Electricity Distribution Input Methodologies GIS Geographic Information System ODRC Optimised Depreciated Replacement Cost ODV Optimised Deprival Valuation ORC Optimised Replacement Cost RAB Regulatory Asset Base RC Replacement Cost SKM Sinclair Knight Merz SINCLAIR KNIGHT MERZ PAGE iii OtagoNet’s Asset Adjustment Process Executive Summary On 22 December 2010 the Commerce Commission (Commission) released a document entitled “Commerce Act (Electricity Distribution Input Methodologies) Determination 2010” (EDB IM). The EDB IM outlines a set of modifications (referred to as the “asset adjustment process”) that Electricity Distribution Businesses (EDBs) may choose to undertake to their disclosed 2004 ODVs as part of the process to establish an Initial Regulatory Asset Base (Initial RAB) as defined in clause 2.2.2 of the EDB IM. On 16 March 2011 OtagoNet Joint Venture (OJV) received, from the Commission, a “Notice to supply information to the Commerce Commission Section - 53ZD of the Commerce Act 1986” (Section 53ZD Notice). Associated with this Section 53ZD Notice was the requirement that OJV supply an Independent Engineer’s Report in respect of the asset adjustment process used for setting its Initial RAB. The exact requirements of this report are contained in “Schedule C: Information Requirements for Engineer’s Report” of the Section 53ZD Notice. Sinclair Knight Merz (SKM) was retained by OJV to review the changes to its 2004 ODV and to prepare an Independent Engineer’s Report in accordance with Schedule C of the Section 53ZD Notice. SKM issued an initial report 1 that OJV included in their submission to the Commerce Commission. The Commerce Commission subsequently requested additional information/explanation in relation to modifications to multipliers and SKM and issued a second report 2 . The timeline associated with the above mentioned Section 53ZD notice was relatively short. As a result OJV has continued to review its 2004 ODV data/information sources, and subsequently requested 3 SKM’s review/consideration of modifications to its 2004 RAB. This is the subject of this report. The following table summarises the differences between OJV’s original 2004 ODV and its adjusted 2004 ODV following the updated asset adjustment process (“Adjusted 2004 RAB”). 2004 ODV Adjusted 2004 RAB 31 March 2004 31 March 2004 ($'000) Replacement Cost (RC) Depreciated Replacement Cost (DRC) 199,732 ($'000) Movement ($'000) 242,121 42,389 17,023 95,536 112,559 198,036 240,164 42,128 Optimised Depreciated Replacment Cost (ODRC) 94,682 111,622 16,940 Optimised Deprival Value (ODV) 91,372 108,312 16,940 Optimised Replacement Cost (ORC) 1 Version 1 dated 26th May 2011. Version 2 dated 28th June 2011. 3 Second letter of instruction issued to SKM dated 14 September 2011 (Refer to Appendix B). 2 SINCLAIR KNIGHT MERZ PAGE 1 OtagoNet’s Asset Adjustment Process The following table outlines the adjustments to OJV’s disclosed valuation over the period 2004 through 2009 (year ending 31 March). Year Value of Adjustments (ODV) SINCLAIR KNIGHT MERZ 2004 2005 2006 2007 2008 2009 $16.940m $0 $0 $0 $0 $0 PAGE 2 OtagoNet’s Asset Adjustment Process 1. Introduction 1.1. Background Sinclair Knight Merz (SKM) was retained by OtagoNet Joint Venture (OJV) to undertake an independent review of the OJV asset adjustment process. SKM’s review was undertaken to determine the appropriateness of the proposed adjustments in respect of the asset adjustment process as set out in clause 2.2.1 of the “Commerce Act (Electricity Distribution Input Methodologies) Determination 2010”, 22 December 2010 (EDB IM). The findings of SKM’s review were documented in a report titled “Independent Engineer’s Report on the Asset Adjustment Process of: OtagoNet Joint Venture”, Version 1, dated 26 May 2011. SKM subsequently issued Version 2 of the report, dated 28 June 2011, which included additional clarifications regarding the modification of multipliers. This report (Version 3) is issued by SKM, at OJV’s request (refer to second letter of instruction dated 14 September in Appendix B), and details an updated independent review. SKM has prepared it with the objective of complying with the requirements for the Independent Engineer’s Report in Schedule C of the Commerce Commission’s “Notice to supply information to the Commerce Commission Section 53ZD of the Commerce Act 1986 (Section 53ZD Notice), dated 16 March 2011. A copy of the signed statement required by the Section 53 ZD Notice is provided in Appendix C. SKM’s review principally considered the following elements of the asset adjustment process: corrections for asset errors; the reapplication of existing asset multipliers; the application of modified asset multipliers; and the reapplication of optimisation or economic value. In comparison to previous versions of SKM’s Independent Engineer’s Report the material changes in this version (Version 3) are those associated with the following: 1) An increase in the geographical area to which the remote multiplier is applied. 2) An increase in the magnitude of the rugged multiplier that is applied. For the previous Independent Engineer’s Report OJV did not supply any information or views relating to the above two issues and simply adopted the values/methodologies used to establish the 2004 ODV. SKM understand that OJV following this path due to time/resource constraints. SINCLAIR KNIGHT MERZ PAGE 3 OtagoNet’s Asset Adjustment Process 1.2. Processes The preparation of this report has been the responsibility of SKM. We have relied upon information and data prepared by OJV. Wherever possible we have sought to verify this data to check its validity. SKM has not conducted field /site visits to confirm the accuracy of OJV’s asset management systems. We note that, during 2010, SKM undertook a field/site visit associated with OJV’s 2010 financial/accounting valuation 4 . During this review SKM undertook a number of sample data checks of OJV’s asset management systems and compared these with assets in the field. We also sampled, using site visits, regions that OJV had defined as rugged. In the interests of accuracy and completeness, there has been interaction between SKM and OJV during the review. This has been undertaken via telephone discussions, email correspondence and direct meetings. 4 “2010 IAS-16 Valuation – Engineering Field Audit/Visit – Balclutha”, SKM Memo dated 9/01/2010. SINCLAIR KNIGHT MERZ PAGE 4 OtagoNet’s Asset Adjustment Process 2. Information Provided by OJV OJV’s 2004 ODV is contained within an MS-Access database which was populated from the company’s asset management systems/databases. OJV supplied SKM with a number of documents/files to support the proposed adjustment to its 2004 RAB, as follows: 2011 Asset Management Plan; 2004 ODV Report; “OtagoNet ODV 31 March 2004 Adjustment for Errors & Omissions”, OtagoNet report. “Distribution Substation Dropout Fuses.xls”, MS-Excel file outlining missing DDO’s. “Regulator Transformers.xls”, MS-Excel file outlining transformer regulators. “Zone Substations with multiplier on all remote assets.xls”, MS-Excel file outlining zone substation assets. “OtagoNet Asset Registers Corrected on 13_5_2011 from original 20.12.04.xls”, MS-Excel file containing a reconciliation between the 2004 ODV and the adjusted 2004 RAB. “OtagoNet Additions and Multipliers.XLS”, MS-Excel file containing a breakdown of the adjustments proposed to establish the 2004 RAB – in the form requested by SKM. This file was superseded by the information that follows. OJV has subsequently supplied the following (over the period 14 September 2011 through 20 October 2011): “OtagoNetSummary_Final_CorrrQuan.XLS”, MS-Excel file containing a breakdown of the adjustment proposed to establish the 2004 RAB – in the form requested by SKM. A quotation and other evidence in relation to the construction of a 29km, 33kV overhead line in rugged terrain, which has included: – A letter titled “33kV Overhead Line – Palmerston to Deep Dell Substation” from Otago Power Services, dated 12 October 2011. – Photographs of the 33kV line route – GIS maps demonstrating the extent of OJVs application of the rugged multiplier to the 33kV line. A map outlining the updated application of the remote multiplier. SINCLAIR KNIGHT MERZ PAGE 5 OtagoNet’s Asset Adjustment Process 3. Consideration of RAB Adjustments This section sets out the adjustments to the OJV 2004 RAB made under the asset adjustment process. 3.1. Load Control Relays Reference EDB IM cl 2.2.1(2)(a). An EDB may designate a load control relay asset owned by an EDB, except a 2009 disclosed asset, as of ‘included’ type. Clause 2.2.1(3) goes on to say that assets to which sub-clause (2)(a) applies may be valued as: its depreciated historic cost as at 31 March 2009; or if there are insufficient records, then its depreciated carrying value from the general purpose financial statements. OJV has not included load control relays in its Adjusted 2004 RAB. SINCLAIR KNIGHT MERZ PAGE 6 OtagoNet’s Asset Adjustment Process 3.2. Correct Asset Register Errors Reference EDB IM cl 2.2.1(2)(b). EDBs may correct asset related errors in the light of new information. The allowable corrections being due to: assets being omitted in error; assets being included in error; assets being incorrectly categorised; and asset ages, quantity, category or locations being incorrectly recorded. OJV identified three asset categories for which asset ages, quantity or locations were incorrectly recorded and five asset categories for which assets were omitted in error during the 2004 ODV process. These are outlined in the following sections. 3.2.1. Value Modified: Reclosers The data extracted from the 2004 GIS extraction produced invalid dates for reclosers which resulted in them having no depreciation deduced in the 2004 ODV database. Table 4 illustrates that correcting the date data reduced the DRC and the ODRC of the reclosers by approximately $1.4M. SKM has reviewed the information relating to this deduction and is satisfied that it is justified. SINCLAIR KNIGHT MERZ PAGE 7 OtagoNet’s Asset Adjustment Process Table 1 Movement in 2004 ODV due to recloser date error Quantity 2004 ODV as disclosed 2004 corrected Total Movement 3.2.2. 69 69 0 RC ($000) 1,863 1,863 0 ORC ($000) 1,863 1,863 0 DRC ($000) 1,863 438 -1,425 ODRC ($000) 1,863 438 -1,425 Value Modified: 11kV cables and LV cables The GIS data extraction process and subsequent database used to establish the 2004 ODV contained 4.7km of LV cable and 6.9km of 6.6/11kV cable. Since the original database was produced, OJVs GIS data has been improved, errors corrected and now includes 10km of LV cable and 9km of 11kV cable constructed before 31/3/2004. Table 2 and Table 3 illustrate the respective movements due to the modification of 11kV and LV cable information. Table 2 Movement in 2004 ODV due to 11kV cable quantity error Quantity RC DRC ($000) ($000) 2004 ODV as disclosed 6.9 596 327 2004 corrected 9.0 882 625 Total Movement 2.1 286 298 Table 3 Movement in 2004 ODV due to LV cable quantity error Quantity RC DRC ($000) ($000 ) 2004 ODV as disclosed 2004 corrected Total Movement 3.2.3. 4.7 10.0 5.3 297 636 339 ORC ($000) 596 882 286 OR C 143 339 196 ($0 00) 297 636 339 ODRC ($000) 327 625 298 OD RC ($0 00) 143 339 196 Assets Omitted in Error: Distribution Substation Fuses Item (e) on Page 37 of the ODV Handbook specifically notes that the standard pole mounted transformer costs do not include the costs associated with distribution drop out fuses (DDOs). OJV did not include, as a separate item, these DDOs in its 2004 ODV and thus propose to include them in its Adjusted 2004 RAB. OJV has determined the number and type of DDOs omitted based on the distribution transformer information in its original 2004 ODV database. The distribution transformer manufactured dates have been used to determine the ages of the DDOs. SKM has reviewed the information provided by OJV and consider the approach taken by OJV to be sensible and justified. SINCLAIR KNIGHT MERZ PAGE 8 OtagoNet’s Asset Adjustment Process Table 4 illustrates that 4,060 DDOs were omitted and have now been included with a total ODRC of $4.0M 5 . 3.2.4. Assets Omitted in Error: Regulating Transformers During the 2004 ODV process sixteen regulating transformers contained within OJV substations (and one spare) were identified and valued. However, two line regulating transformers 6 adjacent to the Naseby substation were omitted in error. OJV proposed as part of the update to include these in the Adjusted 2004 RAB. SKM understands that OJV has used the nameplate data for the regulating transformers to establish the installation dates (for depreciation purposes). Table 4 illustrates that two regulating transformers were omitted and are now included with a total ODRC value of approximately $0.1M. SKM has reviewed the information relating to these additions and is satisfied that they are justified. 3.2.5. Assets Omitted in Error: Kiness Structure This assessment was based on updated information supplied by OJV over the period 14 September 2011 through 20 October 2011. During OJV’s 2004 ODV process, 31 Substation structures associated with OJV substations were identified and valued. However, the structure at Kiness 7 which contains six air break switches and two reclosers was omitted in error. OJV now proposes to include this in the Adjusted 2004 RAB. The average commissioning date of the assets at Kiness is 6 May 1992 and was used to establish the age of the structure. Table 4 illustrates that that the Kiness Structure has a total ODRC value of approximately $10K. SKM has reviewed the information relating to these additions and is satisfied that they are justified. 3.2.6. Assets Omitted in Error: Streetlight ICPs This assessment was based on updated information supplied by OJV over the period 14 September 2011 through 20 October 2011. During OJV’s 2004 ODV process, 15,299 ICPs were identified and valued. However, 2,414 ICPs which relate to streetlights were omitted in error. OJV now proposes to include these in the Adjusted 2004 RAB. The age of the street light ICPs has been taken from the age of the low voltage to which they are connected and each ICP has been valued using a 2004 Handbook cost of 5 This ODRC figure excludes the application of multipliers which are included in Section 3.3. OJV’s script that dumped information from its Geographic Information System (GIS) did not have the functionality to detect line regulators. 7 The substation asset list was compiled manually and this structure was overlooked. 6 SINCLAIR KNIGHT MERZ PAGE 9 OtagoNet’s Asset Adjustment Process $70. Table 4 illustrates that the Streetlight ICPs have a total ODRC value of approximately $44K. SKM has reviewed the information relating to these additions and is satisfied that they are justified. 3.2.7. Assets Omitted in Error: Distribution Substation MDIs This assessment was based on updated information supplied by OJV over the period 14 September 2011 through 20 October 2011. Items (e), (f) and (l) on page 37 of the 2004 ODV Handbook specify the equipment that is included in the standard costs associated with a distribution substation. This does not include any metering or maximum demand indicators (MDIs). This equipment was omitted in error from OJV’s 2004 ODV. OJV now proposes to include 184 MDIs in the Adjusted 2004 RAB. The age of the MDIs has been taken from the distribution transformer age, which is believed to be conservative as the MDIs will generally be newer than the transformer which they are monitoring. Table 4 contains the details of the MDIs that were omitted and have now been included, with a total ODRC value of approximately $35k. SKM has reviewed the information relating to this addition and is satisfied that it is justified. Table 4 Summary of movements in 2004 ODV due to asset register errors Asset Quantity RC DRC ORC ODRC ($'000) ($'000) ($'000) ($'000) 4,060 8,546 3,958 8,549 3,958 Regulating Transformers 2 103 97 103 97 Kiness Structure 1 13 10 13 10 2,414 169 44 169 44 Distribution Substation DDOs Streetlight ICPs Substation MDIs 184 147 35 147 35 Reclosers 0 0 -1,425 0 -1,425 11kV cable 2 286 298 286 298 LV cable 5 339 196 339 196 6,668 9,603 3,213 9,606 3,213 Total Movement 3.3. Reapplication of Asset Multipliers Reference EDB IM cl 2.2.1(2)(c). EDBs may reapply multipliers where more accurate information has become available. OJV proposes to make three adjustments to its application of multipliers that were used in its 2004 ODV. These are: apply the remote multiplier to zone substation assets; SINCLAIR KNIGHT MERZ PAGE 10 OtagoNet’s Asset Adjustment Process redefine the boundary for remote assets; redefine the regions to which the rugged multiplier is applied; and increase the magnitude of the rugged multiplier. 3.3.1. Re-apply an existing multiplier: Remote multiplier applied to Zone Subs OJV’s 2004 ODV only applied a remote multiplier to selected zone substation equipment 8 . The equipment selected for remote multiplier application was that associated with line equipment (i.e. reclosers, ABS, DDOs). OJV has reviewed the 2004 zone substation costs, considered vehicle travel times & staff accommodation requirements and is of the view that remote multipliers should have been applied to a wider range of zone substation equipment. Given the related costs OJV proposes to apply a remote multiplier of 1.15 9 to all equipment in the following zone substations: Ranfurly, Wedderburn, Oturehua, Brothers Peak, Paerau Power House, Craiglyn Station, Patearoa, Middlemarch, Deepdell, Hyde, Waipiata, Paerau, Stoneburn, Redbank, and Palmerston All of the above substations are located in excess of 75kms from OJV’s contractor works depots. Table 5 illustrates that the proposed adjustment increases the 2004 RAB by $0.6M in terms of ODRC. SKM has reviewed the proposed expansion of the remote multiplier and considers it to be appropriate. 8 9 A remote multiplier was applied to four reclosers at the Ranfurly substation. For the 2004 ODV, OJV only applied a remote multiplier (1.15) to lines in these locations. SINCLAIR KNIGHT MERZ PAGE 11 OtagoNet’s Asset Adjustment Process Table 5: Remote multiplier: Application to zone substation assets Asset Site Development and Buildings Transformers Transformers - Extended Life 33 kV Outdoor Circuit Breakers 22/11kV Outdoor Circuit Breakers Feeder Outdoor Switchgear Transformer Protection and Controls Feeder Protection and Controls Outdoor Structure Concrete SCADA and Communications Equipment Ripple Injection Plant DC Supplies, batteries and inverters Total Movement 2004 ODV - All zone substations Adjusted 2004 RAB - All zone substations 3.3.2. Quantity - RC DRC ORC ODRC ($'000) 342 24 94 83 57 78 43 58 116 64 144 7 ($'000) 269 12 29 38 38 29 26 32 55 45 70 4 ($'000) 342 24 94 83 57 73 43 58 116 64 144 7 ($'000) 269 12 29 38 38 28 26 32 55 45 70 4 1,110 647 1,105 646 29,307 30,417 15,740 16,387 29,209 30,314 15,708 16,354 Re-apply an existing multiplier; remote multiplier region extended Figure 1 illustrates a high level image of the overhead lines to which OJV applied a remote multiplier during the 2004 ODV process. For the 2004 ODV the distance used to define the remote multiplier was measured from Palmerston or Balcutha (whichever was less) and the distance was based on a linear (i.e. as crow flies), rather than road travel distance. Whilst reviewing the 2004 ODV database OJV discovered that a portion of its network had been omitted in error, and this error was corrected in the Independent Engineer’s Report issued 28 June 2011. OJV have subsequently reviewed the above assessment and over the period 14 September 2011 through 20 October 2011submitted to SKM updated information, which is discussed below. The 2004 ODV handbook defines remote areas as “those which are situated more than 75km from the ELB’s or the ELB contractors nearest works depot”. OJV’s works depot and those of its contractors are primarily in Balcutha (39 staff) and Gore (29 staff). There are small depots in Palmerston (8 staff) and Ranfurly (8 staff), which primarily undertake maintenance/operational tasks, for example, preventative maintenance, reactive maintenance (faults) and vegetation management. These small depots are not equipped to undertake significant construction projects, particularly of the scale outlined in the 2004 ODV Handbook. SINCLAIR KNIGHT MERZ PAGE 12 OtagoNet’s Asset Adjustment Process OJV proposes to correct this error and apply a remote multiplier of 1.15 to line assets that are greater than 75kms from the Balclutha/Gore depots. Figure 2 visually illustrates the extent of the area that has been included/corrected, which includes a group of lines between Palmerston and Deepdel (≈41kms of sub-transmission line and ≈184kms of 11kV distribution line). SKM is of the view that the re-classification of these assets (to remote) in OJV’s Adjusted 2004 RAB is reasonable. The following Table 6 illustrates the extent of the proposed adjustment leading to an increase of $1.3M in terms of ODRC. Examination of Table 6 shows that the remote multiplier has also been applied to switchgear, distribution transformers/substations and customer service connections. Table 6: Reapply existing remote multiplier to extended area Asset Quantity Subtransmission lines and cables Distribution Lines and cables Distribution Switchgear Distribution Transformers Distribution Substations LV Lines and cables Customer Service Connections 41 184 1,016 762 781 40 3,104 Total Movement 5,928 SINCLAIR KNIGHT MERZ RC DRC ORC ODRC ($'000) ($'000) ($'000) ($'000) 423 113 423 113 1,083 527 1,077 523 536 200 536 200 454 276 450 274 141 83 136 80 176 90 176 90 44 18 44 18 2,857 1,307 2,840 1,296 PAGE 13 OtagoNet’s Asset Adjustment Process Figure 1: 2004 ODV remote multiplier: overhead lines Figure 2: Adjusted 2004 RAB remote multiplier: overhead lines Adjusted Remote Multiplier Area SINCLAIR KNIGHT MERZ PAGE 14 OtagoNet’s Asset Adjustment Process 3.3.3. Re-apply an existing multiplier; rugged multiplier region extended Figure 3 illustrates a high level image of the overhead lines to which OtagoNet applied the rugged multiplier during the 2004 ODV process. For the 2004 ODV, OJV relied on contractor/staff experience to identify specific sections of line, totalling 435km 10 , located in rugged terrain. Since 2004 OJV has established an improved set of GIS tools and more precise geographic information (i.e. land terrain overlays). These improvements have been used to better define rugged areas. A large proportion of OJVs lines are located in these rugged areas, which cover some 40% of its franchise area, due to the historic practice which saw lines built from farm to farm across country without any attempt to follow the roads. Figure 4 illustrates a high level image of the overhead lines to which OJV now proposes to apply a rugged multiplier of 1.2 11 . The proposed updates result in the rugged multiplier being applied to an additional 1,326 km of line (making a total of 1,771 km of rugged lines). SKM has undertaken a number of random checks (using topographic/road maps) of the regions to which OJV proposes to apply rugged multipliers and has not identified any significant issues. We are in agreement with OJV that line construction in the locations reviewed/indentified would incur additional cost due to difficult access. We note that SKM undertook a field audit of the rugged regions identified during OJV’s 2010 financial/accounting valuation. During the field audit SKM noted that the magnitude of the proposed rugged multiplier was relatively low when one considers that OJV owns lines located in very rugged terrain which are regularly exposed to snow/ice. This proposed change to the regions to which the rugged multiplier is applied results in an increase of $3.4M in terms of ODRC. 10 11 Total overhead line length of 4,077km in the 2004 ODV. For the 2004 ODV OJV applied a rugged multiplier of 1.2 to lines in rugged locations. SINCLAIR KNIGHT MERZ PAGE 15 OtagoNet’s Asset Adjustment Process Table 7: Reapply existing rugged multiplier to extended area Asset Quantity Subtransmission lines and cables Distribution Lines and cables Distribution Switchgear Distribution Transformers Distribution Substations LV Lines and cables Customer Service Connections 237 1,085 5 - Total Movement 1,326 RC DRC ORC ODRC ($'000) ($'000) ($'000) ($'000) 2,260 779 2,195 765 5,511 2,594 5,511 2,594 34 7 34 7 7,805 3,381 7,740 3,367 Figure 3 2004 ODV rugged multiplier: overhead lines SINCLAIR KNIGHT MERZ PAGE 16 OtagoNet’s Asset Adjustment Process Figure 4 Adjusted 2004 RAB rugged multiplier: overhead lines The calculation methodology employed (to arrive at the adjustments outlined above) for a number of overhead line categories is illustrated in the following Table 8. Table 8 contains the following different breakdowns: the 2004 ODV (red), the 2004 Adjusted RAB (green), and the associated modified value. Note that Table 8 indicates identical line lengths for the 2004 ODV and the 2004 Adjusted RAB and that the remote and rugged multipliers have been applied to different line lengths. SINCLAIR KNIGHT MERZ PAGE 17 OtagoNet’s Asset Adjustment Process Table 8: Sample calculations: Re-apply an existing multiplier Original 2004 ODV Component Type 66kV Line Medium - Primary - Concrete 66kV Line Medium - Primary - Wood 33KV Line Light - Primary - Concrete 33KV Line Light - Primary - Wood 11kV LINE Light - Primary - Concrete 11kV LINE Light - Primary - Wood LV LINE MEDIUM 4 Wire - Primary - Concrete LV LINE MEDIUM 4 Wire - Primary - Wood LV LINE MEDIUM 2 Wire - Primary - Concrete LV LINE MEDIUM 2 Wire - Primary - Wood Length Standard Life Remaining Life km Years Years 60 60 41 14 45 28 192 60 29 306 45 12 1,626 60 26 939 45 21 46 60 19 25 45 12 13 60 20 24 45 10 RC per km ($000) 69 69 45 45 26 25 42 42 36 36 TOTAL Remote kms Rugged kms RC 1.15 1.2 ($000) 60 0 4,745 14 0 1,096 90 45 9,581 76 128 15,210 306 174 43,326 341 159 25,716 0 0 1,921 0 0 1,057 0 0 452 0 0 856 888 506 103,959 ORC ($000) 4,745 1,096 9,211 14,576 43,326 25,716 1,921 1,057 452 856 102,955 DRC ($000) 3,263 682 4,708 4,148 18,581 11,990 600 285 148 182 44,586 ODRC ($000) 3,263 682 4,482 3,941 18,581 11,990 600 285 148 182 44,153 Length Standard Life Remaining Life km Years Years 60 60 41 14 45 28 192 60 29 306 45 12 1,626 60 26 939 45 21 46 60 19 25 45 12 13 60 20 24 45 10 RC per km ($000) 69 69 45 45 25 25 42 42 36 36 TOTAL Remote kms Rugged kms RC 1.15 1.2 ($000) 60 51 5,274 14 12 1,225 91 123 10,114 85 277 16,281 320 863 45,994 359 523 27,164 2 0 1,934 1 1 1,071 1 0 459 2 2 875 934 1,854 110,391 ORC ($000) 5,274 1,225 9,767 15,584 45,994 27,164 1,934 1,071 459 875 109,346 DRC ($000) 3,638 769 4,942 4,370 19,750 12,834 604 288 151 187 47,532 ODRC ($000) 3,638 769 4,730 4,150 19,750 12,834 604 288 151 187 47,100 Length Standard Life Remaining Life km Years Years - RC per km ($000) TOTAL Remote kms Rugged kms 1.15 1.2 0 51 0 12 0 78 9 150 13 689 18 364 2 0 1 1 1 0 2 2 48 1,349 ORC ($000) 529 129 556 1,008 2,668 1,447 13 14 7 19 6,391 DRC ($000) 375 87 234 222 1,169 844 4 3 3 5 2,946 ODRC ($000) 375 87 248 209 1,169 844 4 3 3 5 2,947 2004 Adjusted RAB (Greater Application of Same Multipliers) Component Type 66kV Line Medium - Primary - Concrete 66kV Line Medium - Primary - Wood 33KV Line Light - Primary - Concrete 33KV Line Light - Primary - Wood 11kV LINE Light - Primary - Concrete 11kV LINE Light - Primary - Wood LV LINE MEDIUM 4 Wire - Primary - Concrete LV LINE MEDIUM 4 Wire - Primary - Wood LV LINE MEDIUM 2 Wire - Primary - Concrete LV LINE MEDIUM 2 Wire - Primary - Wood Modified Value Component Type 66kV Line Medium - Primary - Concrete 66kV Line Medium - Primary - Wood 33KV Line Light - Primary - Concrete 33KV Line Light - Primary - Wood 11kV LINE Light - Primary - Concrete 11kV LINE Light - Primary - Wood LV LINE MEDIUM 4 Wire - Primary - Concrete LV LINE MEDIUM 4 Wire - Primary - Wood LV LINE MEDIUM 2 Wire - Primary - Concrete LV LINE MEDIUM 2 Wire - Primary - Wood 3.3.4. RC ($000) 529 129 533 1,071 2,668 1,447 13 14 7 19 6,432 Re-apply a modified multiplier: Rugged This assessment was based on updated information supplied by OJV over the period 14 September 2011 through 20 October 2011. Reference EDB IM cl 2.2.1(2)(d). EDBs may make adjustments to multipliers in accordance with specific new multiplier ranges. SKM understands that OJV have reviewed their historical projects and found that network construction in rugged areas is not reflective of the 1.2 rugged multiplier that was used for the 2004 ODV. Having said this, OJVs historical projects generally involve refurbishment/upgrade of existing network assets and are not of significant scale. Whilst useful, these projects are not suitable for establishing multipliers in accordance with the 2004 ODV Handbook. At SKM’s request OJV has obtained a contractor quote to build a 29km, 33kV line from Palmerston to Deep Dell which is considered to traverse across typical rugged terrain faced by SINCLAIR KNIGHT MERZ PAGE 18 OtagoNet’s Asset Adjustment Process OJV. Appendix D contains the details associated with the quote, coupled with calculations undertaken to arrive at a rugged multiplier of 1.6. SKM has reviewed the documents/information provided by OJV and is of the view that it is reasonable. SKM specifically note that OJV’s network is subjected to regular snow and ice, which SKM expect would result in more robust structural line designs. The proposed change to the magnitude of the rugged multiplier results in an increase of $8.4M in terms of ODRC. Table 9 illustrates a breakdown of the changes by asset category. Table 9 Rugged multiplier modified from 1.2 to 1.6 Asset Subtransmission lines and cables Distribution Lines and cables Distribution Switchgear Distribution Transformers Distribution Substations LV Lines and cables Customer Service Connections 366 1,390 5 - RC ($'000) 6,854 14,092 68 - Total Movement 1,761 21,014 3.4. Quantity DRC ORC ($'000) ($'000) 2,297 6,677 6,164 14,091 15 68 8,475 20,836 ODRC ($'000) 2,240 6,164 15 8,418 Re-apply Optimisation and/or Economic Value Test Reference EDB IM cl 2.2.1(2)(e). EDBs may reconsider the application of optimisation based on the network conditions during 2009. OJV has not proposed any optimisation or EV adjustments to its 2004 RAB. 3.5. Other Issues OJV discussed the following valuation issues with SKM and provided SKM with additional information over the period 14 September 2011 through 20 October 2011: Zone transformer replacement costs. OJV are of the view that the zone transformer replacement costs adopted for the 2004 ODV were too low. The increases proposed by OJV have not been reviewed or included by SKM in the Adjusted RAB on the basis that Commerce SINCLAIR KNIGHT MERZ PAGE 19 OtagoNet’s Asset Adjustment Process Commission’s asset adjustment process does not make allowance for changes in asset replacement costs. The Magnitude of the Remote Multiplier; OJV supplied SKM with a set of quotes for undertaking line construction work in remote areas, but they did not support a change to the magnitude of the Remote Multiplier. Land Values; OJV are of the view that the costs associated with land values used in the 2004 ODV were too low. Again SKM has not reviewed or included adjustments to land values in the Adjusted RAB on the basis that Commerce Commission’s asset adjustment process does not make allowance for changes in asset replacement costs. Optimisation; OJV discussed some minor changes to optimisation. However SKM has not reviewed any evidence and no adjustments to optimisation have been undertaken. SINCLAIR KNIGHT MERZ PAGE 20 OtagoNet’s Asset Adjustment Process 4. Summary OJV’s asset adjustment process has focused on three areas: including assets that were excluded in error during the 2004 ODV; correcting an error in relation to area of application of remote multipliers; and adjusting the boundary/regions for the rugged multipliers application. Table 10 below summarises the impact on OJV’s Adjusted 2004 RAB arising from the asset adjustment process. Table 10: Summary of asset adjustment process Asset RC ($'000) 2004 ODV DRC ($'000) ORC ($'000) ODRC ($'000) ODV ($'000) 199,732 95,536 198,036 94,682 91,372 - - - - - Correct Asset Registers 9,603 3,213 9,606 3,213 3,213 Re-apply Existing Remote Multiplier 3,967 1,954 3,945 1,942 1,942 Load Control Relays Re-apply Existing Rugged Multiplier Increase Rugged Multiplier to 1.6 Adjusted 2004 RAB Net Movement in RAB SINCLAIR KNIGHT MERZ 7,805 3,381 7,740 3,367 3,367 21,014 8,475 20,836 8,418 8,418 242,121 112,559 240,164 111,622 108,312 42,389 17,023 42,128 16,940 16,940 PAGE 21 OtagoNet’s Asset Adjustment Process Appendix A Table Summary of Asset Value Adjustments: Schedule A4 EDB Name Disclosure Year Ended OtagoNet Joint Venture 31 March 2010 SCHEDULE A4: ASSET ADJUSTMENT PROCESS row 6 Summary of Engineer's Valuation Adjustments (at time asset enters regulatory asset register) 7 8 Asset adjustment process - adjustments 2004 * ($000) 2005 ($000) 2006 ($000) 2007 ($000) 2008 ($000) 2009 ($000) Ref 9 10 Include load control relays 11 Correct asset register errors for 2004 ODV assets 12 Dropouts at Transformer Sites 13 Recloser date correction 11kV/LV cables, Regulators, Kiness, ICPs & MDIs 14 16 Correct asset register errors for 2005 – 2009 assets 17 Insert details of asset or similar asset type Insert details of asset or similar asset type Insert details of asset or similar asset type 19 3,958 (1,425) 680 3,213 15 18 2.2.1(2)(a) – 20 21 22 23 2.2.1(2)(b) – – – – 2.2.1(2)(b) Re-apply an existing multiplier to 2004 ODV assets Apply remote multiplier of 1.15 Apply rugged multiplier of 1.2 1,942 3,367 24 5,309 25 26 27 2.2.1(2)(c) Re-apply a modified multiplier to 2004 ODV assets Apply rugged multiplier of 1.6 8,418 28 29 30 31 32 33 34 8,418 2.2.1(2)(d) – 2.2.1(2)(e) Re-apply optimisation or EV tests to 2004 ODV assets Insert details of asset or similar asset type Insert details of asset or similar asset type Insert details of asset or similar asset type 35 36 37 38 Total value of adjustments by disclosure year 16,940 – – – – – * Includes assets which first entered the regulatory asset register in a disclosure year prior to 2004. 39 SINCLAIR KNIGHT MERZ Page 6 PAGE 22 OtagoNet’s Asset Adjustment Process Appendix B OJV’s Instructions to Engineer SINCLAIR KNIGHT MERZ PAGE 23 ùtagoNet Postal - POBox 1586 . lnvercargill9340 . NewZealand Office - g2CharlotteStreet.Balclutha.Ph03 4184950. Fax03 4190141 J \ 14 September 2011 Richard Fairbairn Manager Power Systems Sinclair Knight Merz Limited PO Box 9806 Newmarket Auckland 1010 Dear Richard Following on the work undertaken in May this year, we have further reviewed the assessment of OtagoNet's Regulatory Asset Base (RAB) and identified a number of areas where further improvements and corrections can be made. We have advised the Commerce Commission that this work is underway. ln order to allow easier reconciliation, we have used the 2004 ODV as the starting point, i.e. we have encompassed the work already undertaken by OtagoNeVSKM and summarised in your report "lndependent Engineer's report on the Asset Adjustment Process of: OtagoNet Joint venture" dated 26 May 2011. ln summary the changes proposed from the 2004 ODV include: o o ¡ o . . . o ¡ Correction of date error for 69 Reclosers Changes to the multipliers used and the assets they are applied to Correction of data for I I kV and LV cables Addition of assets not included in 2004 ODV, e.g. Transformer fuses, Regulators, Kiness structure, MDls and Streetlight lCPs Alterations to the multipliers lor Zone substations Alterations to the values used for Zone substations power transformers Changes to Optimisation Changes to land values Addition of depreciation from 20041o 2009 to correct RAB to 311312009. We invite you to review the work undertaken and to review and re-issue your report in light of the proposed changes. Your report would be in the form of an independent Engineers Report consistent with the requirements of schedule C of the "Notice to Supply lnformation to the Commerce Commission Section 53ZD of the Commerce Act 1986'. Given the tight timeframes, please advise when you could undertake this work and your proposal for fees. Could you please direct your response or any queries to Mr Wayne Stronach at Marlborough Lines, phone 03 579 3813, who has reviewed the database and subsequent valuation on behalf of OtagoNet. Yours sincerely Martin Walton Ghief Executive Otago\ Iet L7 May 2011. Richard Fairbairn Sinclair Knight Merz 25 Teed Street PO Box 9806 Newmarket Auckland 11-49 Dear Richard Re: lnitial RAB: Engineers Report Thank you for your proposal to provide an lndependent Engineers Report establishment of OtagoNet's lnitial Regulatory Asset Base (RAB). in relation to the We require you to review the changes that we have made to our 2004 ODV and confirm that they meet with the requirements of asset adjustment process outlined in Clause 2.2.L of the Commerce Commission's lnput Methodology Determination. These adjustments include: r ' r r Asset error adjustments Replacement cost multipliers Optimisation Economic value adjustments of an lndependent Engineers Report that meets with the requirements specified in Schedule C of the "Notice to Supply lnformation to the Commerce Commission Section 53ZD of the Commerce Act 1986" which was issued to the OtagoNet Joint SKM's output would be in the form Venture on 16th March 2011. ln order to assist your review we would make available all the necessary information/resources and key personnel. Regards Greg Buzzard Chief Fina ncial Officer OtagoNet’s Asset Adjustment Process Appendix C Signed Statement by Engineer SINCLAIR KNIGHT MERZ PAGE 24 Sinclair Knight Merz PO Box 9806 Tel: +64 9 928 5500 Newmarket 1023 Fax: +64 9 928 5501 Auckland New Zealand Web: www.skmconsulting.com Greg Buzzard, Chief Financial Officer Network Managed by PowerNet Ltd 251 Racecourse Road PO Box 88 Invercargill New Zealand 1 November 2011 ZP01068 Dear Sir, Statement Regarding Independent Engineer's Report on the Asset Adjustment Process of OtagoNet Joint Venture Introduction Sinclair Knight Merz Ltd (SKM) was requested by OtagoNet Joint Venture (OJV) to undertake an independent review of proposed adjustments to OJV’s regulatory asset base as at 31st March 2004. This review was undertaken to determine the appropriateness of the proposed adjustments in respect of the process set out in clause 2.2.1 of the “Commerce Act (Electricity Distribution Input Methodologies) Determination 2010”, 22 December 2010 (EDB IM). SKM’s findings are set out in the enclosed report which has been prepared to comply with the requirements for the Independent Engineer’s report in Schedule C of the Commerce Commission’s “Notice to supply information to the Commerce Commission Section 53ZD of the Commerce Act 1986 (Section 53ZD Notice) dated 16 March 2011. This letter incorporates the signed statement required by the Section 53ZD Notice. Confirmation of Independence and Qualifications I, as a chartered professional engineer (as defined in section 6 of the Chartered Professional Engineers Act 2002), can confirm that: 1) SKM has acted independently with respect to OJV and its subsidiaries and affiliates; 2) SKM has significant experience in New Zealand, Australia and the United Kingdom in relation to the valuation of electricity networks for both regulatory and financial reporting purposes. SKM’s review and the preparation of the report have been undertaken by Dr Richard Fairbairn and Mr Stephen Wightman. Dr Fairbairn and Mr Wightman are professionally qualified and experienced in the type of work concerned and are familiar with the OJV network; 3) the report is in writing and accessible in electronic (PDF file-type) format and includes a copy of the written instructions provided to SKM by OJV (included as Appendix B to the enclosed report), including any subsequent variations or modifications; Sinclair Knight Merz Limited The SKM logo trade mark is a registered trade mark of Sinclair Knight Merz Pty Ltd. Offices across Australia, New Zealand, UK, South East Asia, Middle East, the Pacific and Americas OtagoNet Joint Venture Statement Regarding Independent Engineer's Report on the Asset Adjustment Process of OtagoNet Joint Venture 1 November 2011 4) the report includes a table summarising the various asset value adjustments corresponding to Schedule A4 of the Information Disclosure Notice Templates (please see Appendix A to the enclosed report); 5) the report provides the minimum information for each category of asset adjustment outlined in Table 1 of the Section 53ZD Notice, together with such additional information sufficient to allow a reader: i. to understand the data, information, calculations and assumptions employed in respect of each category of asset adjustment; ii. to understand the extent to which professional judgement was exercised by SKM and the effect of that judgement in deriving the resultant asset values; iii. to verify the arithmetical accuracy of the asset adjustment calculations; and 6) the report may be publicly disclosed by OJV pursuant to an information disclosure determination in relation to OJV made by the Commission under section 52P of the Commerce Act (1986). I can confirm that SKM is satisfied that: i. the ODV rules have been properly applied for assets which had not had an ODV valuation calculated originally, as required by clause 2.2.1 of the EDB IM; ii. where values under Generally Accepted Accounting Practice have been relied on, those values have been supplied or reviewed by an appropriately qualified party (e.g. accounting practitioner); and iii. the report meets the requirements of Schedule C of the Section 53ZD Notice. SIGNED on behalf of Sinclair Knight Merz Limited by: R. Fairbairn, MIET, MIPENZ, CPEng Sinclair Knight Merz S. Wightman, MIPENZ Sinclair Knight Merz The SKM logo trade mark is a registered trade mark of Sinclair Knight Merz Pty Ltd. page 2 OtagoNet’s Asset Adjustment Process Appendix D Additional Information The following information outlines a quote to construct a 30km, 33kV, mink conductor line between Palmerston and Deep Dell. Figure 6 illustrates the route/location of the line. Figure 7 illustrates some aerial photographs taken along the line route. The attached quote/letter from Otago Power Services indicates a total 2011 cost of NZ$2.8M which, based on discussions with OJV, can be broken down into the following different route sections: Location Distance 2011 Cost Palmerston to Pole 172942 4.9km $335,808 Pole 172942 to pole 172870 6.7km $995,463 Pole 172870 to pole 172585 11.5km $1,030,475 Pole 172585 to Deepdell 6.8km $472,254 29.9km $2,834,000 Total Comments Relatively easy going but no road frontage Difficult access, long spans, access roads required, rocky country Rolling country, fair access, some long spans Relatively easy going but no road frontage Equates to $95k/km The mink conductor has an equivalent cross-sectional area of 63.1mm2AL, which falls into the 2004 ODV Handbook classification of “33kV Lines – Light (<150 mm2AL)” and has a standard cost of $45k/km. Statics New Zealand publishes a number of inflationary cost indices. Figure 5 illustrates two relevant indices over the 2004-2011 period and which infer a conservative rugged multiplier of: $95k/km / 1.31 / $45k/km = 1.6 A factor associated with “economies of scale” has not been included on the basis that the line length is considerable coupled with the fact that the contractor’s quote includes a number of exclusions. SINCLAIR KNIGHT MERZ PAGE 25 OtagoNet’s Asset Adjustment Process No 0 1 2 3 4 5 6 7 Year 2004 2005 2006 2007 2008 2009 2010 2011 CPI (All Groups Index SE9A) Δ Year Δ Cummulative PPI (Construction) Δ Year Δ Cummulative 1.000 1.000 1.000 1.000 1.028 1.028 1.069 1.069 1.033 1.062 1.062 1.135 1.025 1.088 1.053 1.195 1.034 1.125 1.052 1.257 1.030 1.159 1.030 1.295 1.020 1.182 0.998 1.292 1.045 1.236 1.013 1.310 1.400 1.300 1.200 1.100 1.000 CPI (All Groups Index SE9A) 0.900 PPI (Construction) 0.800 2004 2005 2006 2007 2008 2009 2010 2011 Year Figure 5 Statistic New Zealand: Relevant cost escalation indices SINCLAIR KNIGHT MERZ PAGE 26 OtagoNet’s Asset Adjustment Process Figure 6 Palmerston to Deepdell: 33kV line location and OJV multiplier map SINCLAIR KNIGHT MERZ PAGE 27 OtagoNet’s Asset Adjustment Process SINCLAIR KNIGHT MERZ Figure 7 Palmerston to Deepdell: Typical difficult rugged terrain PAGE 28 Marlborough Lines Limited 1 Alfred Street, PO Box 144, Blenheim 7240 New Zealand Telephone 0-3-577 7007 Facsimile 0-3-579 3806 Email info@linesmarl.co.nz 12 October 2011 Otago Power Services Quotation Ref: 203398.7 OtagoNet Limited PO Box 1586 INVERCARGILL 9840 ATTENTION: Terry Jones Dear Mr Jones 33kV Overhead Line- Palmerston to Deep Dell Substation Thank you for your enquiry regarding an estimate of costs for construction of a three phase 33kV overhead line. As requested we have undertaken an estimate of the cost for construction of 29.9km of line from Palmerston to Deep Dell. In doing this we have based our pricing on the current line construction, but on the basis that: It is a ‘green fields’ site The conductor required is ‘Mink’ All poles will be Treated Pine and wind stays be applied to suit current design requirements Where the requirement is to drill and blow holes we have allowed to do this once only at each hole site. Due to the conditions on site it may take more than once to get the hole to depth. Our quotation for this construction work is $2,834,302.00 Plus GST. The breakdown of our costs is: Materials Labour Plant/ Vehicles Creditors/Subcontractors $ 727,194.00 $ 1,138,926.00 $ 163,052.00 $ 805,130.00 TOTAL (excluding GST) $ 2,834,302.00 Please note that we have allowed for all civil work required within our cost. This includes an allowance for the establishment of tracks to some sites but depending on landowner requirements this component of the cost will need to be considered may alter. Excluded from our costs are the following. Surveying and pegging the line route and pole sites. The cost of establishment to site. Establishment of any easements or agreements and any associated compensation payments. Any alterations to existing lines crossing any proposed route or the cost of shutdowns associated with these crossings. Any Tree felling or clearing. Our estimate detailed above allows for all work to be carried out at one time. Should it be expected that parts of this job be done at separate times then additional costs will be incurred. If you require any further details we would be pleased to assist. Yours sincerely Steve McLauchlan General Manager OPSL