Attachment 1 Calculation of ESB Power Generation Revenue under the Annual Bulk Power Agreement TABLE OF CONTENTS 1. INTRODUCTION 1 2. OVERVIEW 3 3. TREATEMENT OF PEAT PLANTS 4 4. CONTROLLABLE COSTS 4 5. MARKET DRIVEN COSTS AND REVENUES 6 6. ALLOWED FUEL COSTS 7 7. TREATMENT OF VARIATION IN TOTAL VOLUME PRODUCTION 10 OTHER ISSUES 10 8. APPENDIX 1 APPLICATION OF INTEREST 12 APPENDIX 2 DETERMINATION OF MONTHLY FUEL VALUES 13 2 APPENDIX 3 FIXED VARIABLE ELEMENTS OF FUEL INDEXATION FORMULAE 21 APPENDIX 4 INFORMATION PROVISION 23 APPENDIX 5 NON RECURRING STATION COSTS 25 1. Introduction and Summary This paper set out the details of the transfer pricing mechanism between PG and PES for the sale of output. The following points 1 to 14 summarise the highlights of this bulk transfer arrangement. This Agreement covers the sale of electricity from PG to PES for the period from 1st January 2002 to 18th February 2005 inclusive. The provision of other PG services to the market (e.g. Top Up, the Virtual IPP scheme, Ancillary Services, System Support, Emergency Generation and Capacity Margin) are not included in this Agreement. However PG’s allowable revenue under this Agreement will be adjusted to take account of revenues earned by PG through the provision of these services. PG’s allowable revenue is calculated as PG’s total allowable costs less other regulated revenues earned in the market. Any deferred PG allowable revenues and interest thereon that is not being recovered in any one year will be allowed to be recovered via the tariffs of the following years. Under Section 39 of the Electricity Regulation Act, 1999, (as amended by the Sustainable Energy Act, 2002) the Minister shall by order direct the Commission to impose Public Service Obligations on ESB and other parties. This Order provides for the recovery of additional costs associated with ESB’s peat fired stations. This Order will take effect on January 1, 2003. PG’s allowable revenues have been amended to take this into account. All settlement shall take place at the Trading Point and all output, demand and prices shall be determined at this point. Subject to Clause 2, PG will recover from PES any additional charges levied on PG associated with PG providing output to PES under this Agreement. PG’s allowable revenue has been set out on a €/MWh basis and shall comprise both a controllable and a market driven component. This price shall be profiled by time of day and season. The fuel component makes up the largest part of the market driven costs. The initial fuel component is compared to indexed outturn figures for each month. Each month a revised fuel component is calculated. This indexation process takes account of changes in a basket of specific fuel indices. For the purposes of this Agreement, the weighting for each fuel type included in the basket is calculated as expected output by fuel type expressed as a percentage of PG’s total output. PES and PG shall review and agree these weightings annually prior to submitting them to the Commission for approval. Changes in the fuel prices for a particular month will be forwarded by PG to both PES and CER. An annual reconciliation process will be used by PG and PES to determine and agree the overall financial under/over 1 recovery to be factored into the following years PG charges to PES for use in tariff determinations. Due to the interaction between the gas and electricity markets PG may, on occasion, incur additional gas costs as a result of following dispatch instructions. The Commission shall ex post review these costs to correct, as appropriate. Other reasonably incurred market driven costs including emergency generation and rates are passed though to PES. Costs such as transmission use of system charges will be passed through in full to PES. Where the market driven costs and revenues are greater or less than the forecast values the difference passed through to the BPA will be the net value. Controllable costs will be indexed to CPI and or the Programme for Prosperity and Fairness - with in built efficiency factors. The Agreement price may need to be adjusted for the volume of all PG sales, e.g. if sales to PES, VIPP and top up, differ substantially from the forecast levels. 2 2. Overview The BPA revenue that PG can derive from sales to PES is based on PG’s estimated allowed costs, regulated market revenues (i.e. revenues not related to the sale of electricity from PG to PES) and VIPP and Top Up sales discounts. The estimated allowed costs are made up of Controllable Costs, Market-driven Costs and Fuel Costs. The regulated market revenues consist of payments for constraints, Top Up and Secondary Top Up, VIPP, system support, ancillary services and capacity margin. For year t ESB PG will estimate its annual costs, regulated market revenues and VIPP/Top UP discounts and will submit these estimates to the Commission for approval in May of year t-1, along with the annual sales forecast from PG to PES as agreed by both parties. Following approval of the amounts by CER, a BPA revenue for year t will be determined. At the same time (i.e. May year t-1) ESB PG will submit a revised forecast for year t-1 and a final outturn for year t-2 if applicable. In formulating the transfer price for year t any net adjustment (K factor), arising from the revised forecast of year t-1 and the final outturn of year t-2 verses the amounts recovered/recoverable in these years, will be included. All K factors will be recovered with interest as set out in Appendix 1. The timetable for the process is detailed below. Pre 2002 Pre 2002 May 2002 Sept 2002 May 2003 Sept 2003 May 2004 Estimated costs and market revenues for 2002 2002 Tariff determination Estimated costs and market revenues for 2003 Revised forecast of costs and market revenues for 2002 2003 Tariff determination Estimated costs and market revenues for 2004 Revised forecast for costs and market revenues for 2003 Actual outturn of costs and market revenues for 2002 2004 Tariff determination Costs and market revenues for 2005 to be discussed Revised forecast for costs and market revenues for 2004 Actual outturn of costs and market revenues for 2003 The total allowable cost that PG is allowed to recover in any year from PES under this Bulk Power Agreement is calculated in euro million. This euro million estimate is then translated in a €/MWh value that is profiled over time to reflect the different values for electricity at the different times of year. This provides PES with some efficiency incentive. Figure 1 below provides the shape of the profiles for winter, summer and spring/autumn weekdays and weekends that will apply in 2003. 3 Winter Wkday Winter Wkend Summer Wkday Summer Wkend Spr/Aut Wkday 23 21 19 17 15 13 11 9 7 5 3 1 Spr/Aut Wkend Figure 1: Time of Day Profile 3. Treatment of Peat Plants For 2002 the BPA revenue will include revenue associated with PG’s peat plants. From January 1st 2003 these plants will be operated under a PSO levy mechanism (ref: S.I. 217 of 2002). The PSO levy will be a separate charge included on electricity bills from all suppliers and will be collected from all final users of electricity. 4. Controllable Costs Controllable costs are those costs over which PG can influence the outturn value. The Commission has determined PG’s controllable costs as defined in Table 2 below. In any year the allowed amount will only be adjusted for actual inflation verses the inflation assumed in the May t-1 estimates. The allowed values for controllable costs have been capped to incentivise PG to operate efficiently and make cost savings. Any additional expenses incurred will not be passed through to the final customer. Conversely, PG may retain any savings against these values throughout the duration of the price control. 4 Real 2001 Prices1 Payroll Operations and maintenance Non-recurring (minor) Business services Corporate centre Depreciation Employee and public liability Environmental Return on investment Industry restructuring PG Overheads Closure Total € million 2002 2003 2004 * * * 13,121 9,542 92,217 1,039 3,063 75,771 0 0 14,123 * * * 11,132 7,926 71,391 860 5,564 69,771 3,942 -4,876 0 * * * 11,904 7,362 71,391 860 9,957 64,774 3,942 -2,915 0 363,208 288,792 291,957 Table 2. Controllable costs Notes: 1. * these values are not provided individually as PG considers this information to be commercially sensitive. 2. All values are inflated by CPI with the exception of Payroll, Business Services and Corporate Centre Costs. Payroll is inflated by PPF (Programme for Prosperity and Fairness). Business Services and Corporate Centre Costs are inflated by 50% PPF and 50% CPI. If a new National Wage agreement is not reached payroll will be indexed at CPI thereafter. The 2001 Real prices were based on an estimated inflation of 3.5% and will be adjusted to reflect the actual inflation rate. 3. The CER have approved an annual fixed sum for minor non-recurring projects (< €2.5 M). The cost recovery for larger projects will be approved on an individual case basis by CER. 4. PG’s share of Business Services and Corporate Centre costs allocated to peat-fired plant have been included in 2002 and excluded thereafter. 1. 5 Prior to approving these values, CER reviewed estimates provided by PG in its Revenue Submission Revised Forecast 2002 and 2003 Estimate. 1 5. Market Driven Costs and Revenues Market driven costs and revenues are those that are subject to market forces and are, to varying degrees, outside PG’s control. In May of year t-1, PG will submit estimates of all market driven costs and revenues for year t to the Commission for approval. The 2002 forecast and 2003 estimates are detailed in Table 3. Except for non-recurring costs, any variance between the estimate, revised forecast and actual out turn for the costs and revenues in Table 3 will be recovered via the annual K factor. The treatment of non-recurring costs is outlined in Appendix 5. Market Driven Revenue2 2002 2003 Top up and secondary top up 7,866 23,600 180,118 108,960 1,229 1,229 Ancillary services 28,138 28,007 Constraint payments 17,391 17,391 VIPP System support Emergency generation Capacity margin Total € m – real 2001 prices Market Driven Costs Rates Insurance Emergency generation System support Powersave scheme 0 0 30,285 27,399 265,027 206,586 2002 2003 23,815 24,966 8,298 8,298 25,665 11,584 1,229 1,229 782 0 Purchased electricity (Spill) 27,039 16,025 Transmission use of system charges 32,829 28,746 * * Non-recurring Constraint costs 17,391 20,070 Environmental 0 0 Total € m – real 2001 prices * * Table 3. Market Driven Costs and Revenues Revised per PG’s Allowed Revenue Submission Revised Forecast 2002 and 2003 Estimate 2 6 Notes to Table 3: 1. * these values are not provided individually as PG considers this information to be commercially sensitive. 2. In the area of environmental expenditure, during the period of this Agreement PG may face additional legal obligations. Subject to the Commission’s approval, PG will be allowed to pass through all reasonable costs for compliance with all future environmental requirements, including work that has to be carried out as a result of station IPC licence requirements, compliance with emission bubble limits, landfill levy and associated compliance/ mitigation costs, etc. 3. The Commission requires PG to demonstrate to the Commission’s satisfaction that, whilst acting as a Reasonable and Prudent Operator, it maximises the level of revenue or minimises the level of costs included in Table 3 4. The emergency generation costs for the period November 2000 to February 2001 will be recovered in the years 2003 and 2004 6. 5. PG will absorb the difference between the revenue received from VIPP and Top Up as compared with the revenue that would have been received if these products had been sold at the PES price (as determined in this Agreement). The income differential amount, known as the “VIPP and Top Up discount”, will be calculated using actually half hour data. Allowed Fuel Costs Fuel related expenditures are approximately fifty per cent (50%) of ESB PG’s total costs. The Commission, in order to ensure that consumers do not bear the burden of inefficient fuel purchasing, has linked the recoverable fuel revenue to the market price for fuel. The Commission will allow PG to recover the market price of fuel purchased in any given year. ESB PG will carry the risk of any variance between actual costs and the market price for fuel.3 The allowed fuel cost relates to PG’s sales volume less any spill purchases. In April of year t-1, an estimate will be made of PG’s fuel revenue based on forecast market prices for year t and estimated total PG production. This estimate will be used to generate a Reference Energy Price, Pt, and will be an input to the calculation for the Tariffs in year t. In the first year (2002, where t=0), Pt, will be set with reference to the Commission’s proposed profit and loss account for PG as set out in the Commission’s 12th September 2001 paper (with some adjustments reflecting further consideration of points raised at that time). For 2002 P0 is estimated to be € 30.12/MWh ESB PG must document the causes of any significant variances that arise. ESB PG will be permitted to retain explainable gains or losses due to hedging contracts, purchasing agreements, etc. Any unexplainable windfall gains or losses will be recovered / rebated in the following years. 3 7 Under the Grid Code, NG will supply PG with its Committed Outage Programme for year t in October of year t-1. Using this schedule, PG and PES will develop and agree revised fuel mix weightings annually based on an unconstrained dispatch prior to submitting them to the Commission for approval. When the Commission approves these weightings, they will then be fixed for year t. In April of year t-1, using a combination of actual volumes and fuel prices (for January to March of year t-1), together with revised forecasts (for April to December of year t-1), PG and PES will develop and agree a revised forecast of total fuel revenue (i.e. for volume – total sales – spill) in year t-1 prior to submitting them to the Commission for approval. When approved by the Commission, the revised fuel Cost (RFC) will be included in the calculation of PG’s estimated allowable revenue for that year. 12 3 RFC Pact .va PRF .v RF M 4 M 1 where: M is month in t-1 Pact is the P value calculated using fuel weightings developed in October of year t-2, and fuel prices as occurred in the relevant months of year t-1. PRF is the P value calculated using fuel weightings developed in October of year t-2, and forecast fuel prices for the relevant months of year t-1. vRF is the forecast, made in April of year t-1, of monthly volumes of PG sales less spill purchases, regarding months April to December of year t-1 inclusive. va is the actual volumes of PG sales less spill purchases, as occurred in months January to March of year t-1 inclusive. Full details regarding the calculation of P values are given in Appendix 2. 8 Early in year t-1, actual values of all parameters for year t-2 will be known, and the final actual fuel cost AFC can be determined as detailed below: AFC 12 [P M 1 a ct * va ] where: 9 M = month in t-2 Pact = P value calculated using weights developed in October of year t-3 and the actual fuel prices as occurred in each month of year t - 2. va = actual volumes of PG sales less spill purchases as occurred in the relevant months. 7. Treatment of variation in total volume production If PG either sells more or less volume that originally estimated and agreed with PES, this will result in an over or under recovery of allowed revenue via the BPA. Any such variance will be reflected in the annual K factor. If PG’s total production (i.e. sales – spill purchases) either increases or decreases when compared to the original estimate then this will result in a change to the predicted fuel mix used to determine the allowed fuel cost recovery. PG has carried out a sensitivity analysis on its originally model. This analysis indicates that for either an increase or decrease in output of 300 GWh, the change in plant output will be associated primarily with marginal oil and gas plant in a 65/35 split respectively. The table below details the associated composite efficiencies. These values will be used to adjust the allowed fuel costs for any over/under production with respect to the original estimate. Plant type Coal Oil Gas 8. Weight 0 65 35 Efficiency 35.5 35.8 37.2 Other Issues Changes to regulated wholesale prices Changes to the regulated wholesale prices (i.e. top up and spill arrangements) that affect PG’s income will be accounted for in the price control and will leave PG financially neutral. Treatment of gas penalties There are a number of conflicts between the gas and electricity Codes that may result in a generator incurring penalties under the gas code while following the terms of the electricity code. In view of this, an ex-post annual review will take place, for the purpose of PG’s revenue control, to determine allowed revenue based on unavoidable gas penalties. Where approved by the Commission, adjustments will be made to the following year’s calculation of allowable revenue to include any unavoidable penalties incurred. Other Penalties Under the Trading & Settlement Code and the Transmission Use of System Agreement, penalties may be imposed upon PG by the Transmission System Operator. PG may submit these additional costs to the Commission for consideration in the following year’s review. Where approved by the 10 Commission, adjustments will be made to the following year’s calculation of allowable revenue to include any unavoidable penalties incurred. Treatment of deferred income In any year, some of PG’s revenue may be deferred. These values will be recovered in the following year, where the deferred amount will form part of the annual K factor. 11